IBM ITV

Address: Land To The Front Of The London Television Centre, Queen's Walk And Potential Construction Access Routes From Upper Ground London, SE1

Application Numbers: 15/04312/DET; 15/04313/DET; 15/04315/DET; 15/04316/DET.

Case Officer: Richard McFerran

Ward: Bishops

Date Validated: 23rd July 2015

Proposal: Approval of details pursuant to

Condition 7 (Construction Logistics Plan) 15/04312/DET

Condition 8 (Code of Construction Practice) 15/04313/DET

Condition 11 (Pedestrian/Cyclist Management Plan) 15/04315/DET

Condition 12 (Tree Removal Plan) 15/04316/DET of planning permission 14/02792/FUL (Erection of a pedestrian bridge with incorporated garden, extending for a length of 366m over the River Thames from land adjacent to The Queens Walk on South Bank (in the London Borough of Lambeth) to land above and in the vicinity of Temple London Underground Station on the north bank, the structure of the bridge having a maximum height of 14.3m above Mean High Water and a maximum width of 30m; the development also comprising the erection of 2 new piers in the River Thames; erection of a single-storey landing building (incorporating maintenance, management and welfare facilities and up to 410sqm A1, A3 and/or D1 floorspace with additional ancillary service and plant) on land adjacent to The Queens Walk, opposite the ITV building; associated public realm works; works to trees (including the removal of trees); associated construction work (including laying out of a construction access from Upper Ground) and works sites; and works within the River Thames (including temporary and permanent scour protection, relocation of moorings and erection of temporary structures) granted on 19.12.2014 (herein referred to as ‘the Garden Bridge’).

Drawing numbers and Documents:

Condition 7 (15/04312/DET): GB-BYCI-ALL-PLN-CON-00002 Rev 13 (received

24/11/2015) Condition 8 (15/04313/DET): GB-BYCI-ALL-PLN-ENV-00003 Rev 09 (received

24/11/2015) Condition 11 (15/04315/DET): GB-BYCI-INS-ALL-PLN-CON-00005 Rev 09 (received

24/11/2015) Condition 12 (15/04316/DET): TFL/TGB/AMS-SB/02h (dated 9th November 2015)

RECOMMENDATIONS: Condition 7 (15/04312/DET): Grant Approval of Details Condition 8 (15/04313/DET): Grant Approval of Details Condition 11 (15/04315/DET): Grant Approval of Details

SITE DESIGNATIONS

Relevant site designations:

Conservation Area: Southbank Conservation Area (CA 38)

Opportunity Area: Waterloo Opportunity Area

London Plan Policy Area: Central Activities Zone (CAZ)

London Plan Policy Area: Thames Policy Area

Ecology: Site of Metropolitan Nature Conservation Importance – River Thames

Flood Zone: Environment Agency Flood Zone 3

Trees: Tree Preservation Orders

LAND USE DETAILS

Site area 7.2ha (both sides of the river)

Use Class Use Description Floorspace (Gross External Area)

Floorspace prior to demolition

A1/A3/D1 Flexible retail/restaurant/community use

0

Proposed floorspace

A1/A3/D1 Flexible retail/restaurant/community use

410m²

OFFICER’S REPORT Reason for referral to PAC: The applications are reported to the Planning Applications Committee in accordance with (4) of the Committee’s terms of reference.

Condition 12 (15/04316/DET): Grant Approval of Details

Applicant: The Garden Bridge Trust (GBT)

Agent: Emma Barnett (Adams Hendry Consulting Limited)

1 SITE AND SURROUNDINGS

1.1 The Garden Bridge would be located in Central London, providing a new pedestrian river crossing between the South Bank (in the London Borough of Lambeth) and Temple Underground Station on the North Bank (in the London Borough of Westminster). The planning application boundaries occupy an area of 7.2 hectares in total (on both sides of the river), including land required for construction.

1.2 The application site within Lambeth incorporates part of The Queen’s Walk, which forms part of the Thames Path and is identified as a Strategic Walking Route in the London Plan (2015). The Queen’s Walk varies in width and character along its full length. This section is approximately 30 metres wide and comprises two lines of mature trees (subject to a Tree Preservation Order), a paved section with some seating, and a grassed section (with some trees and shrubs) to the rear adjacent to the ITV building. Due to construction issues the application site also encompasses the pedestrian route that links The Queen’s Walk with Upper Ground (between the ITV and IBM buildings) and part of Bernie Spain Gardens, a landscaped public open space. Further clarification on construction options is found within Section 6 of this report.

1.3 To the immediate south of the application site is the ITV television studios and offices, whilst beyond this is a residential area bound by Cornwall Road, Duchy Street and Stamford Street. To the south-east of the site is Gabriel’s Wharf (a mix of shops, restaurants, cafes and bars set around a courtyard), beyond which is Bernie Spain Gardens and the OXO Tower. To the west of the site is the four storey locally listed IBM office building and the Grade II* listed National Theatre.

1.4 The nearest existing river crossings to the site are Waterloo Bridge (250m west) which forms part of the Strategic Road Network (SRN) and Blackfriars Bridge (650m east) which forms part of the Transport for London Road Network (TLRN).

1.5 The application site is located within the Southbank Conservation Area which is described as a nationally important collection of 20th Century buildings fronting the south bank of the River Thames.

1.6 This report deals with a number of planning conditions attached to the planning consent (14/02792/FUL) granted by LB Lambeth in December 2014 for the works falling within its administrative area. A separate consent was issued by Westminster City Council who will subsequently adjudicate on conditions associated with the permission for the works falling within its administrative area.

2 RELEVANT PLANNING HISTORY

2.1 The relevant planning history for the site is listed below, including the parent permission issued by LB Lambeth and the conditions that have been discharged to date.

2.2 14/02792/FUL – Lambeth’s Planning Application Committee (PAC) resolved to grant

planning approval on 11th November 2014. Following referral to the Greater London Authority (GLA), planning permission was granted by LB Lambeth on 19th December 2014 for the erection of a pedestrian bridge with incorporated garden, extending for a length of 366m over the River Thames from land adjacent to The Queens Walk on South Bank (in the London Borough of Lambeth) to land above and in the vicinity of Temple London Underground Station on the north bank, the structure of the bridge having a maximum height of 14.3m above Mean High Water and a maximum width of

30m; the development also comprising the erection of 2 new piers in the River Thames; erection of a single-storey landing building (incorporating maintenance, management and welfare facilities and up to 410sqm A1, A3 and/or D1 floorspace with additional ancillary service and plant) on land adjacent to The Queens Walk, opposite the ITV building; associated public realm works; works to trees (including the removal of trees); associated construction work (including laying out of a construction access from Upper Ground) and works sites; and works within the River Thames (including temporary and permanent scour protection, relocation of moorings and erection of temporary structures). An image showing the approved bridge in context can be found at Appendix 1.

2.3 The above permission was granted subject to a total of 46 conditions and the

completion of a S106 legal agreement. 29 of these conditions are pre-commencement (or prior to specified works) conditions with a number that are specifically required to be referred back to Planning Applications Committee for determination.

2.4 The first package of conditions were submitted to the Local Planning Authority (LPA)

for determination in March/April 2015. These conditions were not required to be referred to PAC for determination and as such they were determined by officers under delegated authority following input from the relevant technical consultees with decisions issued in May/June 2015. Details of these conditions are as follows:

15/01803/DET – Partial approval of details pursuant to Condition 36 (Details of archaeological mitigation –Part A).

15/01836/DET – Approval of details pursuant to Condition 42 (Details of a protocol for the protection of legally protected species).

15/01975/DET – Approval of details pursuant to Condition 32 (Details of a monitoring plan - Flood Defences).

15/02055/DET – Approval of details pursuant to Condition 33 (Details of piling works for South Bank Landing Building).

15/02056/DET – Partial approval of details pursuant to Condition 43 (Details of scheme to deal with site contamination – Parts 1 and 2 only).

2.5 The second package of conditions was submitted to the LPA for determination in late

July 2015 including the PAC referable conditions that are the subject of this report. The submission included 4 tree related conditions which are not PAC referable. These applications are currently pending consideration and will be determined by officers (following input from the Council’s Arboricultural Officer) under delegated authority subject to the approval of the Tree Removal Plan pursuant to Condition 12. The 4 non PAC referable tree related conditions currently pending are as follows:

15/04317/DET – Approval of details pursuant to Condition 13 (Tree Protection Plan).

15/04318/DET – Approval of details pursuant to Condition 14 (Arboricultural Method Statement).

15/04319/DET – Approval of details pursuant to Condition 15 (Tree Service and Drainage Route Plan).

15/04320/DET – Approval of details pursuant to Condition 16 (Details of Tree Protection Monitoring).

2.6 It is noted that the Tree Removal Plan (pursuant to Condition 12), one of the four applications considered under this report, was previously presented to PAC on 15th September 2015. However the item was deferred by PAC members in order for it to be heard alongside other related pre-commencement conditions noting that the site

compound and construction logistics have implications on the number and location of trees to be removed.

2.7 The third package of conditions, largely related to operational issues, was submitted to

the LPA in mid-September 2015. Negotiations between GBT, Lambeth Officers and relevant consultees remain on-going in order to overcome identified issues within the details submitted in support of these applications. Subject to these issues being satisfactorily resolved it is anticipated that this package will be presented to PAC in January or February 2016.

2.8 The fourth and final package of pre-commencement conditions (which have not yet

been submitted at the time of writing) largely relate to the detailed design and layout of the South Landing Building and the interface with the Thames Tideway Tunnel. It is anticipated that these will be reported to PAC in February or March 2016.

3 PROPOSAL

3.1 This report deals with applications that seek to discharge four separate construction related conditions associated with planning permission: 14/02792/FUL which was granted full planning permission in December 2014 for the structure commonly known as the ‘Garden Bridge’.

3.2 The applications currently under consideration seek the approval of details pursuant to the following:

Condition 7 (Construction Logistics Plan) 15/04312/DET

Condition 8 (Code of Construction Practice) 15/04313/DET

Condition 11 (Pedestrian/Cyclist Management Plan) 15/04315/DET

Condition 12 (Tree Removal Plan) 15/04316/DET

3.3 A series of technical documents have been submitted pursuant to each of the above conditions. The information within each document is intended to satisfy the reasons why each condition was considered necessary in the first instance in order to provide further details of aspects of the development that were not fully described in the original application submission. The full wording of each condition is included within each individual assessment section. Each of these conditions were requested to be reported back to PAC for determination.

3.4 The technical, detailed nature of many of the subject areas addressed within the

details submitted alongside these conditions ensures there is a degree of overlap between the issues that they are trying to address. In assessing these applications, issues have been assessed against the most relevant condition. For the purposes of clarification, all documents submitted in support of these 4 applications have been revised in order to address specific concerns arising from the consultation process.

3.5 It should be noted that Condition 10 (Noise and Vibration Strategy – 15/04314/DET) is

not considered under this report. This condition was specifically imposed in order to provide robust mitigation of noise and vibration impacts on neighbouring development. This condition is particularly intended to mitigate against the impact upon ITV and IBM, who immediately adjoin the application site and are therefore identified as the most sensitive receptors.

3.6 Negotiations on the noise mitigation measures remain on-going at the time of writing in order to seek agreement between relevant parties on the broad principles of how

suitable mitigation will be achieved. Once these mitigation measures are tested and the results found satisfactory the Noise and Vibration Strategy will be updated and the details will be reported to PAC. For the purposes of clarification, officers are of the opinion that the Noise and Vibration Strategy can be considered independently from the four applications that are addressed within this report. This is on the basis that details pursuant to these four conditions are interlinked with the location and size of the site compound and how it is accessed and serviced having a direct correlation with how pedestrians and cyclists are safely managed in the vicinity of the site and the number of trees that are required to be removed. This is discussed in further detail within the assessment of Condition 8, the supporting document for which has been amended to signpost the fact that the site specific noise and vibration measures will be secured under Condition 10.

3.7 For the purposes of clarification, the officer advice in relation to the pre-application and

application stages for the conditions and legal obligations associated with the parent planning permission have been structured through a Planning Performance Agreement (PPA).

4 CONSULTATION

Garden Bridge Trust Consultation

4.1 As part of the original resolution to grant planning permission the Chair of PAC was

clear in the instruction that there was an expectation for Garden Bridge Trust (GBT) to carry out a thorough consultation process with local stakeholders and residents in relation to the pre-commencement conditions and S106 obligations attached to the parent permission. To this end the following consultation measures were approved by the LPA and undertaken by GBT in advance of the submission of these applications:

Technical, Statutory and Local Stakeholders

Individual meetings with 22 technical and local stakeholders (including local housing groups, community groups, ward councillors, businesses, and infrastructure providers)

Local Community

Over 7,000 leaflets and questionnaires distributed to local residents and businesses.

Three drop-in events within the Waterloo Area (one mid-week session, one evening session and one weekend session) for members of the public to ask questions of the GBT technical team.

A Community Forum for representatives of local organisations.

A consultation website including the full range of draft documents available for viewing and comment.

4.2 Consultation feedback was facilitated via a freepost questionnaire included with the

leaflet, whilst responses were also made via email or submitted through the GBT consultation website. The applications pursuant to these conditions are accompanied by a ‘Construction Consultation Report’ which explains how public and stakeholder

feedback has been considered and where possible it has been taken into account in finalising the submission documents. The ‘Construction Consultation Report’ can be viewed on the Council’s website alongside the other documents submitted in order to discharge these conditions.

LPA Consultation 4.3 In addition to the above, officers considered it prudent for the LPA to undertake its own

separate public consultation. Members should note that there is no statutory requirement for the LPA to consult on applications for approval of details reserved by planning conditions. However given the scale of interest in the parent application and the criticism in relation to public engagement on that application it is considered that an additional consultation exercise was considered to be beneficial.

4.4 The LPA’s consultation exercise included the distribution of 229 letters to residential

properties and businesses within the surrounding environs. This includes residential properties and businesses on Upper Ground, Cornwall Road, Stamford Street, Duchy Street, Coin Street and Waterloo Road.

4.5 A further 37 consultation letters/emails were also sent to local housing co-operatives,

residential amenity groups and local stakeholders within the area surrounding the application site.

4.6 In addition to the above a press notice was published in the South London Press on 7th

August 2015 and 6 site notices were erected within the vicinity of the site. 4.7 Consultation with external statutory organisations including Transport for London (TfL)

and Port of London Authority (PLA) also took place, together with consultation with relevant internal technical officers including Transport Planning, Environmental Health and Arboriculture.

4.8 Specific consultation responses are reported separately under each individual

assessment section within this report. 4.9 It is acknowledged that there were two separate technical issues associated with

Lambeth’s Public Access website over the course of the consultation period for this particular package of conditions. However both issues were temporary and considered to be swiftly addressed and as such are not considered to undermine the quality or effectiveness of the LPA’s consultation exercise.

4.10 A ‘technical panel’ presentation was made on 24th August 2015 and 30th November

2015 to PAC members and ward councillors in order to fully explain the details pursuant to the four conditions under consideration within this report.

5 RELEVANT PLANNING POLICY

5.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise.

5.2 The National Planning Policy Framework was published in 2012. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development. It is a material consideration in the determination of all applications.

5.3 The development plan in Lambeth is the London Plan (2015) and the Lambeth Local Plan (September 2015). The Local Plan contains detailed development management policies and site allocations. The Local Plan was submitted for examination to the government in March 2014. This process included a public hearing in July 2014 and has continued with the Inspector issued her final report in August 2015. The Local Plan was formally adopted by Council on 23rd September 2015 when it superseded the Core Strategy (2011) and saved UDP policies (2007) and was given full weight in the determination of planning applications.

5.4 The key policies of the Local Plan that are considered relevant in the assessment of

each condition are listed within each individual assessment section of the report. For the purposes of clarification, the relevant Local Plan policies that are applicable to each application are considered to be similar to the superseded policies in the UDP and Core Strategy which are listed within the ‘reason’ for each individual condition. It is therefore considered that the Local Plan policies do not introduce new objectives which would not be met by these applications to discharge conditions.

6 ASSESSMENT: Application Ref: 15/04312/DET - Condition 7 (Construction

Logistics Plan)

Introduction

6.1 Condition 7 of the parent application (14/02792/FUL) reads as follows: No development shall commence until such time as a Construction Logistics Plan

(CLP) for the project has been submitted to and approved in writing by the Local Planning Authority. The CLP shall demonstrate how the proposed construction has endeavoured to optimise use of the river, prevented prolonged closure of the Queen's Walk and minimised the use and associated closure of Bernie Spain Gardens. The development shall thereafter only be constructed in accordance with the Construction Logistics Plan.

Reason: To ensure that the Construction Logistics for the bridge minimise nuisance and disturbance in the interests of the amenities of adjoining occupiers and of the area generally, and to avoid hazard and obstruction to the public highway (Core Strategy Policies S4, S5 and PN1 and Saved UDP Policies 7, 9 and 50). [Note: The details submitted pursuant to this condition will be referred to Lambeth's Planning Applications Committee for a resolution].

6.2 No formal decision had been made on how the Garden Bridge would be constructed

by GBT at the time of the determination of the parent planning application as the contractor had not yet been appointed. However three different possible construction options were reported to PAC for the southern portion of the bridge and the associated

South Landing Building involving a combination of land based and marine works. The three separate construction options were as follows:

Option A. Access via the pathway between the IBM/ITV buildings. The Queen’s Walk

would remain open except for short periods necessary for construction of temporary works and the southern sections of the garden bridge.

Option B. Access using Bernie Spain Gardens. It would necessitate closing Queen’s

Walk between Bernie Spain Gardens and the IBM building, with the pedestrian diversion to be around the ITV/IBM buildings.

Option C. Maximising use of the River Thames by utilising light equipment and

conventional building materials only. From a construction logistics perspective this would be preferred. To do this would necessitate closing Queen’s Walk between the IBM building and Gabriel’s Wharf for duration of the works.

6.3 Given the lack of clarity on construction methodology, the potential impact upon the

safety and operation of surrounding highways and strategic pedestrian walking routes, the impact that different construction options would have upon the amenities of adjoining occupiers and the general wider area, it was considered appropriate to include a condition which required a Construction Logistics Plan (CLP) to be submitted and approved in writing prior to the commencement of work.

6.4 The purpose of a CLP is to help manage construction in a way which reduces the

negative effects of construction work on local residents, businesses and the wider environment. A detailed CLP, such as that submitted in association with this application, provides the local planning authority with the detail of logistics activity expected during the construction phase of the project. CLPs form part of a suite of documents, covering both planning and environmental health legislation, which help ensure that disruption from construction activity is minimised.

Submitted Document

6.5 The applicant has provided a detailed CLP in support of this application. This

document has been revised during the lifespan of this application following comments from Lambeth’s Transport Planning Officer, TfL and responses to public consultation. The main headlines of the document are as follows:

Bernie Spain Gardens will not be used at any time for construction activities. Construction access will utilise the pathway between ITV and IBM. This was referenced as Construction Option A during the consideration of the parent application. Access to the ITV/IBM pathway will be restricted during working hours to construction site access, ITV queues and the IBM and ITV emergency exits.

Queen’s Walk would remain open throughout the construction process other than for 13 temporary short-term closures of up to 24 hours dues to safety reasons. These closures would be limited to outside the weekend peaks of pedestrian movements along Queen’s Walk.

Other than preparatory site works, there would be no works on the South Bank until September 2016 when the site compound would be erected

The hoarding surrounding the site compound would be sited in order to provide a minimum width of 7.6m on Queen’s Walk other than on approximately 10 occasions

were the compound would be temporarily (up to 24 hours) increased in size/footprint thereby reducing the width of Queen’s Walk to 5m.

All materials, plant and equipment for bridge works (as opposed to works to the north and south banks where the bridge will land) will be delivered by water, except for pumped concrete and bentonite which will be pumped from the north and south banks respectively. There would be two peak days of HGV activity of 132 vehicular movements.

Tilbury Docks, Essex (approximately 26 miles downstream from the application site) will be used as a logistics hub for the bridge construction. Tugs will be used to move pontoons and barges between Tilbury and the site. Large sections of the bridge will be assembled in Tilbury, delivered to the site in barges and carefully lifted into position by river based cranes.

All construction plant equipment and materials associated with the works to the South Landing Building will be delivered by road from Upper Ground given the difficulties in transferring goods from barges to the South Bank in this location and the busy nature of Queen’s Walk.

In comparison to the figures presented to PAC during the determination of the original application, over 2,200 vehicle movements will be transferred to river rather than by road. This results in approximately 35% fewer road journeys than if all deliveries were made by road.

The pathway between ITV and IBM will be closed during project working hours, except for IBM emergency access and for audience members to queue to access ITV Studios. A moveable hoarding will be installed to segregate construction traffic from audience queues. The ITV queue will be 2m wide. The moveable nature of the hoarding allows it to be temporarily widened for deliveries if necessary. Large abnormal loads would only be delivered outside queuing times through schedule planning with ITV.

FORS (Fleet Operator Recognition Scheme) accreditation (Bronze Level) will be a mandatory requirement for all UK logistics operators.

Consultation Responses

6.6 At the time of writing 20 objections had been made in relation to this application

including objections from Waterloo Community Development Group (WCDG). The objections are summarised within the below table together with an officer response:

Objection Summary Officer Response

The submitted document does not rule out the use of Bernie Spain Gardens for uses other than construction access.

The submitted document is explicit that the access route to the site compound on the South Bank will be through the pathway between the ITV/IBM buildings. It is unclear what other uses that the objector is referring to, however the use of Bernie Spain Gardens by the applicant for construction access or any other use related to the construction or operation of the Garden Bridge would

represent a breach of planning control and the LPA has powers available to it to remedy any such breach. It should also be noted that the condition specifically deals with construction logistics and members are not being asked to consider non-construction activities which are captured under other conditions.

Queen’s Walk will not remain open throughout the construction period.

Queen’s Walk will remain open throughout the construction period other than on 13 occasions when it will be closed for up to 24 hours at a time. Whilst it would have been preferable for Queen’s Walk to remain open at all times, these limited number of closures are considered to be acceptable noting that they are necessary given the health and safety aspects of erecting a structure which will oversail the pathway. A detailed diversion, involving signposting and marshals, is proposed in order to mitigate against the impact of these temporary closures. Further details of the proposed diversion can be found under Appendix 2.

The document states that there will be no parking on local streets for project personnel and suppliers. However there is no definition of local streets, which if it includes Stamford Street will be contradicted by the fact that Lambeth Council has already increased parking spaces for lorries and coaches in this location. Who will enforce against this ‘no parking’ in the local area.

The term ‘local streets’ is not defined but is considered a general term applicable to all streets within the area surrounding the site. The submitted document is clear that there is no parking for project personnel and suppliers. This is achieved on the basis that there is no designated parking for vehicles either on site or on the surrounding network which falls within the Waterloo Controlled Parking Zone (CPZ). Only permit holders can therefore park in the surrounding network apart from blue badge holders and any ‘pay and display’ bays available for non-CPZ permit holders. However the likelihood of site workers parking in these ‘pay and display’ bays or nearby private car parks is unlikely noting the high public transport accessibility of the site together with the associated high parking costs and the inconvenience of ‘pay and display’ bays only being available for a short period. Lambeth’s Transport Wardens will

enforce against any breaches of parking regulations. Breaches on Stamford Street, which forms part of the Transport for London (TfL) Road Network, will be enforced by TfL. In terms of parking for coaches and lorries in Stamford Street, again it should be noted that TfL are the highway authority for this road which falls within their road network. Lambeth are not responsible for any changes in parking or operation of this road. In any case officers are not aware of any additional parking bays for such vehicles.

Working hours are listed as 8am to 6pm but in reality they are 7am to 7pm with additional working activities taking place within the additional hours. This will have a particular impact on Saturday mornings which is blatantly inconsiderate of residents.

The CLP stipulates that on Monday to Friday there may be a period of up to one hour before (07.00 – 08.00) and after (18.00 – 19.00) core working hours for start-up and close-down activities. There will be no additional hours on Saturday mornings although there may be one hour (13.00 – 14.00) after core working hours. Activities during these hours would not include the use of plant or machinery likely to cause disturbance to neighbouring residents and businesses. Whilst there may be deliveries during these hours and subsequent additional vehicle movements these would not exceed existing background noise levels and it is considered that there would be no harm to the amenity of local residents or the operation of adjoining businesses.

Certain activities will require even longer working hours than those listed within the CLP.

A limited number of activities associated with the construction of the Garden Bridge including the intensive concrete pouring to the river piers and erection of the large structural elements may require longer working hours than those listed within the CLP. These extensions are limited to a small number of events over the construction period and the nature and timing of the extended working hours will be agreed in advance by the Council through an application for prior consent under Section 61 of the Control of Pollution Act 1974 (commonly known as Section 61 Application). Consent for such an application will only be agreed where

clear justification is provided. The impact of out of hours working on local residents will be assessed as part of this process prior to any potential consent being issued.

There is no requirement to notify local residents in advance of construction activities taking place to allow them to plan around disruption.

The Code of Construction Practice being considered under application ref: 15/04313/DET sets out the requirements for notification of local residents throughout the consultation process. Further information is contained under the assessment section of Condition 8 of this report, however in summary a detailed notification procedure will be used including letters/leaflets being sent to all stakeholders and residents (within 14 and no later than 7 days) in advance of works commencing. These letters will introduce the works, explain when and why they are happening, and explain the protocol for raising concerns or queries. In addition to this GBT’s website and social media will be regularly updated whilst a quarterly newsletter will be sent to those who are on the GBT contact database.

The ‘just in time’ approach to prevent vehicles queuing is unconvincing particularly with cement pours requiring a constant supply of cement in order to avoid hardening.

Deliveries to the sites will be planned using appropriate software. The contractor’s partner, FM Conway, has two large depots located within 3 miles of the Garden Bridge site which will be utilised as holding areas for vehicles, including concrete mixers. Effectively vehicles would queue at these sites and the operator would operate a system of calling vehicles to the site only when space is available and to a pre-arranged delivery time. This approach will avoid disruption caused by vehicles queuing including during intensive concrete pours.

In such a cramped and dangerous area it is alarming to think about large vehicles reversing.

Swept path analysis demonstrates that there is a sufficient turning head within the site compound to allow rigid vehicles to enter and exit the site in forward gear. Any reversing vehicles will be overseen by trained banksmen and traffic marshals as an appropriate safety measure.

The presentation of the information is misleading, by multiplying the number of deliveries avoided. It should be presented as savings per day, or per week. The presentation of journeys as ‘one way movements’ is also deliberately misleading as vehicles will also have to leave the site.

The HGV movements listed are one way movements, so the table shows all movements, including each entry and egress from the site during the construction programme. 1 truck equals 2 vehicular movements. The presentation of the information over the course of the construction period allows for direct comparison with the likely vehicular movements presented to PAC during the consideration of the parent application.

Why is there no discussion of the problems of coaches?

The logistics associated with coaches dropping off and picking up passengers within the vicinity of the site is covered by a separate condition (29) which requires the submission of a Coach and Taxi Management Plan. The approval of details application pursuant to this condition (15/05214/DET) has been submitted to the Council under a later package of conditions and will be reported to PAC in due course.

The narrowing of the riverside footpath, which will also be true after construction, will create a dangerous bottleneck for pedestrians and pedestrian movement will be dangerously restricted and no justification has been provided as to why it needs to be narrowed to just 5m.

This issue is covered by the Pedestrian and Cyclist Management Plan (PCMP) which is considered under application ref: 15/04315/DET. Further information is contained under the assessment section of Condition 11 of this report (paragraphs 8.14 – 8.17). In summary amendments have been made to the submitted documents through the assessment period of this application to ensure that the minimum width of Queen’s Walk has increased from 5m to 7.6m between the northern side of the hoarding and the river wall. The width of Queen’s Walk on the eastern side would be 8m between the hoarding and the river wall. It is acknowledged that there will be approximately 10 occasions during the construction phase when Queen’s Walk will be temporarily narrowed to 5m in width. This will be achieved using a moveable hoarding extending from the main site compound. These temporary reductions in width are considered to be an acceptable compromise in order to secure the extended width of 7.6m during the course of the construction

works on the South Bank. In terms of likely pedestrian comfort, using TfL’s Pedestrian Comfort Guidance for London (2010), the comfort level’s reported for this currently unrestricted section of Queen’s Walk is ‘B-’ for a peak weekend afternoon. The same pedestrian flows have been analysed with the proposed restrictions in width resultant from the construction works. The originally submitted CLP proposed a minimum width of 5m for Queen’s Walk. At the weekend peak it was anticipated that this reduced width would result in a pedestrian comfort level of ‘D’. However as a result of negotiation, amendments have been secured to increase the width of Queen’s Walk subsequently increased to 7.6m throughout the construction period (other than 10 limited occasions when the width is temporarily reduced to 5m). This is turn increases the amount of clear footway that can be walked on and resultantly the pedestrian comfort level during the weekend peak would improve to ‘C+’. This has been reviewed by the Council’s Transport Officer who considers this to be an acceptable outcome. It should also be noted that the PCMP proposes further mitigation measures to help improve pedestrian comfort along this section of Queen’s Walk during the construction phase, including a signposted diversion to encourage pedestrian flows away from Queen’s Walk and potentially removing street furniture and covering tree pits to increase the amount of clear footway available to passing pedestrians. As a result of these additional mitigation measures pedestrian comfort along this section Queen’s Walk would improve further. On this basis it is considered that the Queen’s Walk would not become overly congested as a result of the reduced width and a suitable pedestrian flow would be maintained. It is also noted

that the submitted plan (GB/BYCI/SLB/ALL/DWG/TEC/00410 Rev 07) demonstrated that the size of the site compound has been reduced as much as possible in order to accommodate a suitable turning head, site welfare, crane and appropriate circulation space.

Vehicles leaving the site will cause a safety issue for pedestrians whilst the access routes to the site would include Cornwall Road which would conflict with TfL’s proposals to designate this as part of their cycling ‘Quietway’.

This issue is covered by the Pedestrian and Cyclist Management Plan which is considered under application ref: 15/04315/DET. Further information is contained under the assessment section of Condition 11 of this report. In order to ensure cyclist safety, the site entrance will be managed by trained traffic marshals to ensure that vehicles only enter and exit the site when it is safe to do so. In relation to the ‘Quietway’, TfL considers that the use of Cornwall Road as a construction access route does not conflict with the proposed introduction of a cycling ‘Quietway’ in this location. This is due to the relatively small volume of construction vehicle movements projected at the site and TfL do not consider the interaction between construction vehicles and the ‘Quietway’ to be a major safety concern noting that construction vehicle movements will be largely confined to outside cycling peaks.

There are local residents with health problems who rely on the RV1 bus along Upper Ground for travel. This will adversely affect them if there are any diversions.

There are no proposals to divert the RV1 as a result of the Garden Bridge project.

All deliveries should be made via the North Bank where there is not the same level of construction activity.

There is a significant amount of construction activity proposed for the north landing site where a similar site compound will be required, albeit there is no landing building proposed in this location with the structure landing on the roof of Temple Underground Station. All concrete and bentonite for the northern section of the bridge will be pumped from the north bank and construction activities from the North

Bank will require the closure of Temple Place. The use of the river for logistics has been maximised as much as possible including the delivery and erection of the major structural elements of the bridge. However concrete and bentonite for the bridge structure and materials for the South Landing Building cannot be delivered via river and will require delivery from the South Bank.

The disruption caused by the proposed construction works will severely limit the flow of pedestrians along Queen’s Walk and along Upper Ground which will severely compromise businesses located within Gabriel’s Wharf.

The issue of pedestrian flows is covered under the Pedestrian and Cyclist Management Plan which is considered under application ref: 15/04315/DET. Further information is contained under the assessment section of Condition 11 of this report. However it is not considered that the construction works will severely limit pedestrian flows along Queen’s Walk or Upper Ground. As such it is not considered that the impacts of construction activities on pedestrian flows will have a detrimental impact upon businesses within Queen’s Walk.

The Pedestrian Comfort Level does not appear to have taken ‘static activity’ into account from people taking photographs/admiring views. When this is also taken into account it will significantly worsen Pedestrian Comfort Levels.

GBT have advised that the proposed retained section of Queen’s Walk has been tested to ensure static pedestrians have been accounted for in the pedestrian comfort assessment. Both the Council’s Transport Planning Officer and TfL have raised no concerns regarding the methodology used to calculate Pedestrian Comfort Level.

The width of Queen’s Walk will not be returned after the completion of construction and removal of hoardings due to the location of the South Landing Building.

The principle of the size and siting of the South Landing Building and the subsequent width of Queen’s Walk post-construction has already been accepted by the LPA and is not a material consideration of this application. In any case the width of Queen’s Walk will be returned to 15.7m upon completion of construction works and removal of the hoardings surrounding the site compound.

The 'intention' for all construction related deliveries and collections to be made by FORS (Fleet Operator Recognition

The CLP has been updated since the original submission. It now states that the contractors logistics partner, FM

Scheme) accredited operators is not sufficient. Nor is it acceptable "where practicable" to be compliant with recent CLOCS (Construction Logistics and Cyclist Safety) standards. These should be mandatory.

Conway, have a FORS Gold Standard. This only held by 0.5% of London’s fleet operators and recognises best practice fleet management, including road safety, driver training, cyclist awareness, vehicle specification and CO2 reduction Furthermore, all UK operators who have not achieved FORS must have registered and gained FORS ‘bronze level’ accreditation as a minimum standard within 90 days of an awarded contract. FORS members will be considered favourably in awarding sub-contracts together with those who commit to meet the deadline. Details of the breakdown of anticipated UK operators (FORS accredited) and international operators (non-FORS accredited) will be presented via addendum. In terms of CLOCS standards, it is acknowledged that deliveries and collections will only be compliant with CLOCS standards ‘where practicable’. However this is not a mandatory requirement and there are no grounds for the Local Planning Authority to refuse the application on this basis. It should also be noted that, in order to help safeguard cyclists safety, the CLP stipulates that all construction related deliveries and collections carried out by vehicles over 3.5T will be fitted with a range of vehicle safety measures including: seven side sensors which surround the vehicle and detect objects within 0.8m and track their location and proximity to the vehicle; cameras to allow real-time views of blind spots; side-guard rails, audible ‘vehicle turning left’ warnings; and reflective markings and strobe beacons to the rear of the vehicle.

The proposed construction route compromises the emergency exits on the flank elevations of the ITV/IBM buildings given the reduced width of this pathway and the potential for moving vehicles.

The CLP has been updated to address this. Emergency procedures and routes for ITV and IBM will be maintained throughout the project. IBM access to an emergency exit will be protected, there will be access points designed into the hoarding and any work around the ITV site is being designed with the

need for emergency access. Site staff, in particular banksmen and traffic marshals would assist in the event of an emergency and emergency plans will be drawn up and regular communications will be maintained.

If the bridge is constructed the environment on this stretch of the South Bank will be horrendous for pedestrians and protected river views will be lost forever.

This objection relates to the principle of the bridge as opposed to any issue related to the details pursuant to this condition. The objection is therefore not a consideration in the assessment of this application.

The numbers of people visiting the Garden Bridge once complete will spoil people’s enjoyment of the Queen’s Walk and the South Bank and affect businesses within Gabriel’s Wharf.

This objection relates to the principle of the bridge as opposed to any issue related to the details pursuant to this condition. The objection is therefore not a consideration in the assessment of this application.

This is not a suitable location for yet another pedestrian bridge. It should be relocated to another section of the River Thames.

This objection relates to the principle of the bridge as opposed to any issue related to the details pursuant to this condition. The objection is therefore not a consideration in the assessment of this application.

The bridge will completely detract from views along the river including protected and iconic views of St Pauls and the City.

This objection relates to the principle of the bridge as opposed to any issue related to the details pursuant to this condition. The objection is therefore not a consideration in the assessment of this application.

There will be increased litter and crime resultant from increased numbers of people visiting the Garden Bridge.

Issues relating to waste management and crime prevention will be covered under Conditions 25 (Waste Management Plan) and 38 (Crime Prevention Statement).

The amount of money being spent on the Garden Bridge is immoral and would be better put to other uses such as increasing provision of social housing.

This objection relates to the principle of the bridge as opposed to any issue related to the details pursuant to this condition. The objection is therefore not a consideration in the assessment of this application.

6.7 The Council’s Transport Planning Officer was also consulted on the submitted details.

Following clarification on certain issues and the submission of details he has raised no objections.

6.8 Transport for London were also consulted on the submitted details. Following clarification on certain issues and the submission of details it has raised no objections.

6.9 The Port of London Authority were also consulted on the submitted details. No

response had been received at the time of writing.

Relevant Planning Policy 6.10 As discussed at para 5.6 the Lambeth Local Plan now has been adopted. The policies

within the Local Plan that are considered to be relevant to this application are listed as follows:

Lambeth Local Plan (September 2015)

Policy D2 Presumption in favour of sustainable development

Policy T1 Sustainable Travel

Policy T2 Walking

Policy T3 Cycling

Policy T5 River transport

Policy T7 Parking

Policy T8 Servicing

Policy EN1 Open Space

Policy E4 Sustainable Design and Construction

Policy Q2 Amenity

Policy PN1 Waterloo

Assessment

6.11 The reason listed within the wording of the original condition is clear that the

condition was considered necessary in the first instance in order to minimise nuisance and disturbance from construction logistics to adjoining occupiers and the wider area, as well as mitigating against harm upon the safety and operation of the surrounding highway network. Three separate construction options, including a possible option utilising nearby Bernie Spain Gardens, were presented as part of the parent application. The Construction Logistics Plan (CLP) was therefore imposed to provide clarification on these construction matters.

6.12 The purpose of a CLP is to help manage construction in a way which reduces the

negative effects of construction work on local residents, businesses and the wider environment. A detailed CLP, such as that submitted in association with this application, provides the LPA with the detail of logistics activity expected during the construction phase of the project. CLPs form part of a suite of documents, covering both planning and environmental health legislation, which help ensure that disruption from construction activity is minimised.

6.13 The CLP (and associated appendices) submitted alongside this application is

available to view on the Council’s Public Access Database using the reference number: 15/04312/DET.

6.14 The CLP is highly detailed and covers a wide range of issues. Noting the comments

made during PAC when the parent application was determined, together with the relevant consultation responses, members should note the following issues to be addressed by the CLP:

Provide details on the overall construction programme.

Demonstrate that the construction works would not result in the prolonged closure of Queen’s Walk.

Demonstrate that Bernie Spain Gardens would not be used at any time for construction activities.

Maximise the use of the river for construction logistics.

Minimise the use of road movements in order to reduce the impact of construction logistics on local residents.

Demonstrate that that construction logistics will be managed in order to minimise the impact upon the safety and operation of the surrounding highway network.

6.15 The submitted CLP has been assessed by the case officer in conjunction with the

Council’s Transport Planning Officer noting the specific transport and highways issues. The comments of TfL, together with those submitted as part of the consultation exercise.

6.16 The CLP explains that the overall construction programme for the bridge will be a

period of approximately 32 months, 3 months shorter than the indicative programme submitted with the parent application. The CLP also explains that there would be no works on the South Bank until September 2016 when the site compound would be erected over the grassed area in front of the ITV building. This ensures that there would be no additional impact on the South Bank during the busy summer season.

6.17 With respect to the impact upon Queen’s Walk as a result of construction activity, it is

noted that there are no prolonged closures as per the original PAC resolution. Construction logistics have been designed to ensure that closures of Queen’s Walk are kept to an absolute minimum and limited to 13 separate occasions of up to one day each. These temporary closures are considered necessary to facilitate particular elements of the construction works including the lifting and installation of the southern section of the Garden Bridge.

6.18 The original condition is clearly worded with the stipulation that there should be no

prolonged closures of Queen’s Walk. The temporary closure of the pathway to 13 separate occasions throughout a lengthy construction period is considered to comply with this requirement noting that the scale of the project and the proximity of the bridge’s south landing to Queen’s Walk ensures that a degree of disruption is inevitable, particularly on health and safety grounds with sections of the bridge and temporary structures oversailing the pathway. It should be noted that other impacts regarding the operation of Queen’s Walk during construction are considered under the assessment of Condition 11 (Pedestrian/Cyclist Management Plan).

6.19 As discussed, the construction options presented to PAC as part of the determination

of the parent application included a possible option utilising Bernie Spain Gardens. This was considered to be a concern by members and as such Condition 7 was clearly worded to stipulate that construction works should minimise use and closure of Bernie Spain Gardens. The submitted CLP is considered to be compliant with this part of the condition noting that construction access to the site will not be through Bernie Spain Gardens noting that para 1.2.2 states that “the preferred option does not require the use and closure of Bernie Spain Gardens which will remain open to

the public at all times.” Should there be a change in approach in construction methodology that warrants the use of Bernie Spain Gardens, a new application to discharge Condition 7 would be required and would be reported to PAC for determination. The CLP recommended for approval under this application only permits the use of the pathway between ITV and IBM.

6.20 Construction access to the south landing site will instead be provided via the existing

pathway between the ITV and IBM buildings which links The Queen’s Walk with Upper Ground. This access route is shown in further detail within Appendix 4. A moveable hoarding will be used to facilitate the ITV queuing system or temporarily close the pathway when construction logistics require. Swept paths have been provided to demonstrate that this arrangement works for virtually all vehicles that can be expected to access the compounds except for abnormal width loads which will necessitate temporary closure of the pedestrian element of the combined access. Such deliveries would only take place outside queuing times through agreed schedule planning with ITV.

6.21 The CLP has been updated through the assessment period of this application in order to increase the width of the designated area of ITV queues. The queue width would now be 2m and would be located along the western (IBM) side of the passageway. A series of entrances would be punched into the flank ITV boundary wall to provide access to their studios. This is considered to be an acceptable solution given the proposed queue marshalling to suitably manage the interface with construction access. The queuing areas both within ITV’s demise and the designated queue area would have a capacity of approximately 1800 people ensuring that it will not spill out onto Upper Ground and interfere with the movements of passing vehicles and pedestrians.

6.22 In terms of optimising the use of the river for construction of the bridge, again officers

are satisfied that such use has been optimised as much as is reasonably possible. The CLP (para 3.5.7) states that “in order to optimise the use of the river, all materials, plant and equipment for bridge works on the river platforms will be delivered by water, except for pumped concrete and bentonite.” As a result, the majority of the major works associated with the construction works will take place via the river.

6.23 A marine logistics support base will be established at Tilbury Docks where the

majority of deliveries will be made for onward river transport to the site. In addition, the major bridge structural elements will be pre-fabricated in Italy, partially assembled at Tilbury Docks, brought down the Thames to the site and jacked into place from the river. This maximisation of river based activity substantially reduces the potential impact on the South Bank site and its immediate vicinity. Indeed in comparison to the draft construction methodology originally presented to PAC, the optimisation of the river for construction logistics results in a reduction in over 2,200 vehicle movements.

6.24 It is noted that the concrete and bentonite to be used in the construction in the

southern section of the building will be pumped from the south landing construction compound. For practical reasons these materials need to be delivered to the site by road as opposed to by river. The concrete pouring in particular will require a particularly intensive peak in vehicular movements given that concrete needs to be continuously poured. The submitted CLP stipulates that this will involve 132 vehicle movements on one day. Whilst this is a significant number of movements in a short period it is a reduction from the figure (146 vehicular movements) presented within the draft logistics statement forming part of the parent application. This also

represents one (albeit longer, 16 hour) working day within a 32 month construction programme. On average vehicular movements will be significantly less than this as outlined in Appendices C and G of the CLP and officers are satisfied that the disruption will be kept to a minimum.

6.25 The CLP (para. 3.5.1) also stipulates that contractors will facilitate a ‘just in time’

booking system with respect to deliveries by vehicle by utilising storage/holding areas within 3 miles of the application site. This approach will avoid situations where vehicles need to park or queue on the highway around the application site thereby minimising disruption. This can be properly enforced by Lambeth’s Parking and Highways Teams noting that the Council will receive advanced notice of the specific details of the construction programme as per para. 3.6.9 of the CLP.

6.26 Another betterment within the CLP as opposed to the scenarios presented under the

parent application is in relation to how construction staff will access the site. Initially the expectation was that this would be by road and platforms via the Queen's Walk. Now the proposal is for staff to access from the river until the commencement of piling and concreting, and post that to use temporary footbridges over the Queen's Walk to minimise impacts on the Queen's Walk. The temporary footbridge would have a minimum clearance of 6.8m so not to interfere with pedestrian movements below.

6.27 The CLP also addresses pedestrian and cyclist safety for all construction related

deliveries and collections. It states that it is intended that all such vehicle movements will be undertaken by FORS (Fleet Operator Recognition Scheme) accredited operators (UK operators only) and where practicable, compliant with the most recent CLOCS (Construction Logistics and Cycle Safety Project) standards. Details regarding the breakdown between anticipated UK logistics operators and international operators will be presented via an addendum to provide clarity in relation to FORS accreditation.

6.28 The CLP explains that the local logistics and traffic management contractor, FM

Conway, maintains FORS Gold accreditation and is one of only three organisations in Europe to have achieved certification to ISO 39001: Road Safety Management Systems which is an international standard recognised at reducing death and serious injury on roads. The PCMP states that the contractor will leverage supply chain relationships to maintain an up to date knowledge of local issues, safety initiative and best practice through CLOCS.

6.29 Access to the construction site would be via Upper Ground. It is considered that the

principle of the use of Upper Ground was established under the parent consent noting that the three separate construction options (A, B and C) all involved the use of Upper Ground. Further details on the proposed routes used by construction vehicles to access Upper Ground can be found in Appendix 5. It is acknowledged that Option C proposed the maximum use of the river for construction. However to facilitate this Queen’s Walk would have been closed through the entire construction period. The proposed use of Option A is considered to be an acceptable compromise noting that Queen’s Walk remains open throughout the majority of the construction period and over a third of the anticipated vehicular movements have been removed through the increased use of the river for logistics.

Conclusion and Recommendation

6.29 In light of the above assessment, together with the consideration of the CLP by Lambeth’s Transport Officers and TfL, officers are able to recommend the approval of the details submitted pursuant to Condition 7 of the parent permission.

6.30 This is on the basis that the main requirements of the original condition have been

complied with and that the submitted details accord with the relevant planning policies. Most notably this includes no prolonged closure of Queen’s Walk, no use of Bernie Spain Gardens, optimisation of the use of the river as opposed to road, and the submission of a sound methodology in limiting disruption resultant from construction logistics to local residents/businesses and minimising the harm to the safety and operation of the surrounding highway.

7 ASSESSMENT: Application Ref: 15/04313/DET - Condition 8 (Code of

Construction Practice)

Introduction

7.1 Condition 8 of the parent application (14/02792/FUL) reads as follows: No development shall commence before full details of the proposed construction

methodology, in the form of a 'Code of Construction Practice', has been submitted to and approved in writing by the Local Planning Authority. The Code shall include details regarding: proposed coordination with other construction projects within the vicinity; the notification of neighbours with regard to specific works; advance notification of proposed road and footway closures that may or will be required; details regarding parking, deliveries, and storage; details regarding dust mitigation; details of measures to prevent the deposit of mud and debris on the public highway; and other measures to mitigate the impact of construction upon the amenity of the area and the function and safety of the highway network. No individual stages of the development process shall begin until provision has been made to accommodate all site operatives', visitors' and construction vehicles loading, off-loading, parking and turning within the site or otherwise during the construction period in accordance with the approved details. The details of the approved 'Code of Construction Practice' must be implemented and complied with for the duration of the construction process.

Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally, and to avoid hazard and obstruction to the public highway. (Policies 7, 9 and 31 of the Saved Unitary Development Plan and Core Strategy Policies S4 and PN1). [Note: The details submitted pursuant to this condition will be referred to Lambeth's Planning Applications Committee for a resolution]

7.2 This condition was originally imposed on the basis that the construction operations

have potential to have significant impacts upon the environment, amenity and safety of local residents, businesses and the general public in the vicinity of the application site. The submitted Code of Construction Practice (CoCp) formalises the best practice measures to be undertaken by the contractor during the construction of the bridge in order to mitigate the impact of construction operations.

7.3 In particular, the CoCP sets out standards and procedures for managing the

environmental impacts during the construction of major projects. It covers the environmental, public health and safety aspects of the project that may affect the interests of local residents, businesses, the general public and the surroundings in

the vicinity of the proposed construction site. The CoCP identifies the main responsibilities and requirements of developers and contractors in constructing their projects. The CoCP also aims to assure residents and other affected parties that impacts on the environment are being taken into account according to best practice.

7.4 As per the wording of the original condition, the CoCP is also expected to set out how

local residents, businesses and occupiers will be notified in advance of construction activities. The standards of construction practice agreed within a CoCP allow the local authority to monitor, control, manage and enforce them on construction sites.

7.5 For the purposes of clarification, the applicant has submitted CoCP (Part B) pursuant

to this condition. CoCP (Part A), which deals with general construction requirements, was submitted with the parent application and as such the details have already been approved by the LPA. This can be viewed within ‘Environmental Statement: Volume 3’ on the Council’s Public Access Database using the reference number: 14/02792/FUL.

Submitted Document

7.6 The applicant has provided a detailed CoCP (Part B) in support of this application.

This document has been revised during the assessment period of this application following comments from Lambeth’s Transport Planning Officer, Environmental Health Officer, TfL and responses to public consultation.

7.7 The main headlines of the document are as follows:

The CoCP identifies a number of large construction projects to potentially dovetail with in order to mitigate the cumulative impact of construction logistics or environmental effects. A register of these projects and relevant contacts would be maintained throughout the process and there would be on-going dialogue through the TfL Construction Co-Ordination Working Group for Blackfriars and Waterloo.

The CoCP details how neighbour notification will work. This includes appointing a dedicated Community Liaison Officer to manage and be responsible for these matters. Communication will take place through a Construction Forum as well as the distribution of letters/leaflets no later than 7 days in advance of particular works/milestones (eg road closures). Social media and quarterly newsletters will also be used to communicate with local communities, together with a monthly ‘ezine’ to all parties listed on the contact database.

A dedicated 24-hour telephone helpline, email and postal address will be established to deal with queries or complaints from the general public. The Contractor will also establish relevant social media contact points. The Community Liaison Officer will establish a contacts log where all issues, queries or complaints will be logged and responded to within 24 hours whilst written correspondence will be responded to within 5 working days.

A dry method of wheel washing will be used as all the lorries will stay on concrete, tarmac or pavement. Where wheel cleaning is required, due to expected space considerations in the site compound it would most effective to use simple procedures such as manual cleaning by the site operatives. Suction road brushes would also be proposed during periods of exceptionally inclement weather.

Deliveries to the sites will be planned using appropriate software. The contractor’s partner, FM Conway, has two large depots located within 3 miles of the Garden Bridge site which will be utilised as holding areas for vehicles, including concrete mixers. Effectively vehicles would queue at these sites and the operator would operate a system of calling vehicles to the site only when space is available and to a pre-arranged delivery time. This approach will avoid disruption caused by vehicles queuing including during intensive concrete pours.

Materials will be stored on site in designated, signed areas. They will be protected to prevent the likelihood of damage which would otherwise become waste. All materials will be stored close to the area where they will be used. They will be planned for delivery “just in time” to limit the amount of materials stored on site in order to minimise land take within the compound. Plant and equipment will be ordered and delivered to site to suit the programmed task.

There would be no parking for project personnel and suppliers. This will be achieved by ensuring there is no designated parking for project vehicles on site or on the surrounding network which falls within the Waterloo CPZ which operates essentially during working hours (Mon to Fri 0830–1830 and Sat 0830–1300) ensuring that parking is for permit holders only apart from blue badge holders and any ‘pay and display’ bays available for non CPZ permit holders.

Works will generally only be lit in the early evening during winter, scheduled night work activities and extended working hours during activities such as major concrete pours and piling to ensure the health and safety of all site operatives and members of the public.

Dust mitigation measures to include regular site inspections which would be increased during activities which would have a high risk of generating dust or in windy conditions. Monitoring units will also be used with their locations based on prevailing

wind conditions. A PM10 alert threshold will be set at 250 μg/m3 over a 15 minute period, as recommended by the GLA SPG, at the site boundary. Readings above this threshold will trigger an immediate site inspection, suspension of operations contributing to the exceedance, and measures taken to mitigate the exceedance.

Additional mitigation measures in relation to air quality include keeping site fences, barriers and scaffolding clean using wet methods, removing materials that have potential to produce dust from site, any materials being re-used on site must be adequately covered, limiting speed on site and preventing dust contaminated water running off site.

In terms of gaseous emissions, the contractor will ensure that all non-road mobile machinery on the construction site will have approved engines that comply with pollutant emission limits stipulated in EU Directive 97/68/EC.

A thorough noise monitoring protocol including an additional monitoring station to the Iroko Housing Co-Op which lies directly opposite the construction access.

Consultation Responses 7.8 At the time of writing 11 objections had been made in relation to this application from

a local resident. The objections are summarised within the below table together with an officer response:

Objection Summary Officer Response

The submitted documents do not provide sufficient clarification on the notification procedure for residents/community in advance of specific construction works.

The CoCP sets out the requirements for notification of local residents throughout the consultation process. In summary a detailed notification procedure will be used including letters/leaflets being sent to all stakeholders and residents (within 14 and no later than 7 days) in advance of works commencing. These letters will introduce the works, explain when and why they are happening, and explain the protocol for raising concerns or queries. In addition to this GBT’s website and social media will be regularly updated whilst a quarterly newsletter will be sent to those who are on the GBT contact database.

Commentary regarding working hours is extremely loose and could easily be abused by the construction teams to change agreed working hours at will.

The hours listed within the CoCP are considered to be suitably clear and are not open to interpretation. A limited number of activities associated with the construction of the Garden Bridge including the intensive concrete pouring to the river piers and erection of the large structural elements may require longer working hours than those listed within the CoCP. These extensions are limited to a small number of events over the construction period and the nature and timing of the extended working hours will be agreed in advance by the Council through an application for prior consent under Section 61 of the Control of Pollution Act 1974 (commonly known as Section 61 Application). Consent for such an application will only be agreed where clear justification is provided. The impact of out of hours working on local residents will be assessed as part of this process prior to any potential consent being issued.

The use used of local sized roads, including Upper Ground, is inappropriate for large delivery vehicles including HGV’s noting that these roads are currently one way in some places with cycling in both directions, and is already hazardous at times. The implications for this huge amount of

The issue of construction logistics to the details pursuant to Condition 7 (Construction Logistics Plan). However, the principle of the use of local roads, particularly Upper Ground, for construction related activities is considered to be established under the parent consent. This is on the basis

new traffic will extend far into adjoining roads and junctions and create hazards for other road and pavement users for a wide area.

that all three construction options (A, B and C) that were presented as part of that application included the use of Upper Ground for construction activities. The appointment of the contractor has provided clarity over the proposed construction methodology. It is proposed that option A is used which includes accessing the site via the ITV/IBM passageway. However the construction methodology also maximises possible use of the river, particularly in relation to the large sections of the bridge deck which will be assembled off-site, floated down river and jacked into position. This in turn has reduced the number of overall vehicle movements, including HGV’s, by 35% from the figures included (for construction option A) within the parent application. The average number of daily HGV movements to and from the site is also considered to be relatively low over the course of the anticipated 32 month construction period, ranging between 2 and 4 movements depending on the particular stage of construction. However it is recognised that HGV movements are concentrated into a number of peak days, including two days with a peak of 132 HGV movements for concrete delivery. For practical reasons this needs to be delivered to the site by road as opposed to by river. Whilst this is a significant number of movements in a short period it is a reduction from the peak figure (146 vehicular movements) presented within the parent application. This also represents two (albeit longer, 16 hour) working days within an anticipated 32 month construction programme. In order to suitably manage deliveries, particularly during these peaks, the contractors will facilitate a ‘just in time’ booking system with respect to deliveries by vehicle by utilising storage/holding areas within 3 miles of the application site. This approach will

avoid situations where vehicles need to park or queue on the highway around the application site thereby minimising disruption. Upper Ground will be accessed via a range of different construction routes as outlined within Appendix 5. In relation to cycling safety, measures are incorporated in relation to construction logistics to mitigate against any safety concerns. This includes ensuring that the junction with the ITV/IBM pathway and Upper Ground is suitably marshalled, using FORS accredited contractors and incorporating a range of technological safety measures for vehicles over 3.5T.

Will the construction team be marshalling ALL affected junctions, ie even ones distant from the construction site which are affected because of this huge increase in traffic, or just the immediate one. If just the immediate one this is inadequate.

Marshalling will only be provided to the junction of the ITV/IBM passageway and Upper Ground. Vehicles will be accessing the site from a range of different directions (as outlined within Appendix 5) and it is unreasonable to expect marshalling to all junctions. It should also be noted that on average, the numbers of daily vehicular movements to and from the site are relatively low and that measures are incorporated to help mitigate against any safety concerns associated with vehicle movements. This includes using FORS accredited contractors (UK operators only) and incorporating a range of technological safety measures for vehicles over 3.5T.

The document seems proud that it is "reducing road journeys" yet goes on to list 2,575 one-way movements. Or, if they were more honest with their data, 6,756 total movements in and out of site. This is huge not only for the immediate site but also for London's streets in general.

The issue of construction logistics to the details pursuant to Condition 7 (Construction Logistics Plan). However, the submitted details clearly stipulate that the use of the river for a significant portion of the construction works, including moving and installing the substantial structural elements of the bridge deck will be carried out via river. It is anticipated that this will reduce vehicular movements to and from the site by 35% in comparison to the figures presented within (construction option A) the parent application. Total vehicular movements are therefore expected to be approximately 4,000.

They claim to support local employment, but I fail to see the sincerity of this claim when the bridge is being manufactured in Italy. I do not believe they have any interest in the local community whatsoever.

This is not a material consideration of this application pursuant to Condition 8 of the parent consent. Benefits relating to local employment opportunities will be secured through the Section 106 legal agreements.

Their claim to "take deliveries outside of peak hours where possible" is deliberately lose and meaningless. It is not in their control when deliveries happen, and even so the "where possible" is a useful disclaimer to totally disregard any implied intent. I do not believe that huge numbers of deliveries and movements will not happen when tourists, commuters, cyclists and schoolchildren are in the vicinity.

The issue of construction logistics to the details pursuant to Condition 7 (Construction Logistics Plan), however due to the nature of the project, the contractor maintains significant control over when construction related deliveries are made. The proposed development is an infrastructure project (with limited ancillary A1/A3/D1 use) as opposed to a new residential or commercial development. There are therefore a limited number of sub-contractors or different ‘trades’ which would be on site at any one time. This helps provide clarity over which construction related operations are happening on site at any one time and the associated vehicular movements. Deliveries will be controlled by a ‘just in time’ booking system. This approach will ensure that vehicular movements to and from the site do not coincide with peak hours.

The CoCP does not adequately demonstrate suitable co-ordination with other large development projects in the vicinity of the site.

The issue of construction logistics to the details pursuant to Condition 7 (Construction Logistics Plan). However co-ordination will be achieved through the project’s ‘Construction Forum’ attended by representatives of local authorities and TfL. The contractor will also be part of TfL’s Construction Co-ordination Working Group (Waterloo and Blackfriars) where contractors from neighbouring developments meet on a regular basis and overlay project plans in order to minimise conflicts in vehicular movements. TfL have been consulted on the application nad have confirmed that they are satisfied with this approach.

Risk assessments should be undertaken at the FM Conway depots to be used as HGV holding areas.

This is not a material consideration of this application pursuant to Condition 8 of the parent consent. The aims of the

construction related conditions are to mitigate against harmful impacts associated with construction in the vicinity of the application site. In any case, the HGV holding areas that are referred to are understood to be established depots. Other than a limited number of intensive peaks, vehicular movements across the anticipated 32 month construction programme are considered to be relatively low.

The numbers of people diverted away from Queen’s Walk onto Upper Ground during the build period will affect businesses within Gabriel’s Wharf.

The issue of pedestrian management is covered under the Pedestrian and Cyclist Management Plan which is considered under application ref: 15/04315/DET. Further information is contained under the assessment section of Condition 11 of this report. However it is considered that the construction works will not severely reduce passing trade to businesses within Gabriel’s Wharf. Indeed it could be argued that the fact that Gabriel’s Wharf is located in close proximity to the application site and provides a linkage between Upper Ground and Queen’s Walk raises the possibility of increased numbers of passing pedestrians using Gabriel’s Wharf as a diversion around the construction compound.

The numbers of people visiting the Garden Bridge once complete will spoil people’s enjoyment of the Queen’s Walk and the South Bank and affect businesses within Gabriel’s Wharf.

This is not a material consideration of this application pursuant to condition 8 of the parent consent.

The amount of money being spent on the Garden Bridge is immoral and would be better put to other uses such as increasing provision of social housing.

This is not a material consideration of this application pursuant to condition 8 of the parent consent.

This is not a suitable location for a bridge which would be more suitable to another stretch of the river such as linking Canary Wharf and Greenwich.

This is not a material consideration of this application pursuant to condition 8 of the parent consent.

There was inadequate consultation with local residents prior to the

Consultation undertaken in advance of the submission of the parent application

determination of the original planning application.

are not a material consideration of this application. Thorough consultation measures were approved by the LPA and undertaken by GBT in advance of the submission of these applications to discharge the construction related pre-commencement conditions. The ‘Construction Consultation Report’ which explains how public and stakeholder feedback has been considered and where possible it has been taken into account in finalising the submission documents can be viewed on the Council’s website.

7.9 The Council’s Transport Planning Officer was also consulted on the submitted

details. Following clarification on certain issues and the submission of further details he has raised no objections.

7.10 The Council’s Environmental Health Team was consulted. They have raised no

objection to the approval of details pursuant to the original condition. 7.11 Transport for London were also consulted on the submitted details. Following

clarification on certain issues and the submission of details it has raised no objections.

Relevant Planning Policy

7.12 As discussed at para 5.6 the Lambeth Local Plan now has been adopted. The

policies within the Local Plan that are considered to be relevant to this application are listed as follows:

Lambeth Local Plan (September 2015)

Policy D2 Presumption in favour of sustainable development

Policy T1 Sustainable Travel

Policy T2 Walking

Policy T3 Cycling

Policy T5 River transport

Policy T7 Parking

Policy T8 Servicing

Policy EN1 Open Space

Policy EN4 Sustainable Design and Construction

Policy EN7 Sustainable Waste Management

Policy Q2 Amenity

Policy PN1 Waterloo

Assessment

7.13 In contrast to Part A, the CoCP (Part B) provides information on the site-specific

measures that are to be adopted as part of the construction process in order to minimise nuisance to the public and safeguard the environment. Part B requirements

should be consistent with the general principles agreed under Part A. The submitted CoCP (Part B) (and associated appendices) can be viewed on the Council’s Public Access Database using the reference number: 15/04313/DET.

7.14 The CoCP is highly detailed and covers a wide range of issues. Noting the

comments made during PAC when the parent application was determined, together with the relevant consultation responses, members should note the following issues to be addressed by the CoCP:

Hours of working;

Co-ordination with other construction projects within the vicinity of the application site;

Notification of neighbours with regards to specific works;

Notification of proposed road and footway closures throughout the construction period; and

Details of how complaints can be made and responded to.

7.15 The submitted CoCP has been assessed by the case officer in conjunction with the Council’s Environmental Health Officer noting the specific environmental issues raised. The air quality considerations of the CoCP have also been independently assessed by Waterman Group. The comments of Lambeth’s Transport Planning Officer and TfL have also been considered as part of the assessment, together with those submitted as part of the consultation exercise.

7.16 In relation to the proposed hours of working, these were included under the general

requirements within CoCP (Part A) which was approved as part of the parent permission. The agreed core hours as per Part A were as follows:

Monday to Friday: 0800 to 1800

Saturday: 0800 to 1300

7.17 CoCP (Part B) expands on this by detailing that there may be an additional one hour period before and after the core hours during which there may be staff on site in relation to start-up and close-down activities. These additional start up and close down periods are considered to be acceptable noting the support of the Council’s Environmental Health Officer, these activities are not noise intensive, are not extended into noise sensitive hours, and the closest residential properties to the south bank construction compound are approximately 125m from the application site and are shielded by the ITV and IBM buildings.

7.18 The CoCP also explains that there may be limited days when specific construction

activities will require extended working hours. Permission for these permissions will be dealt with via Section 61 applications for ‘Prior Consent to Works’ which are assessed under The Control of Pollution Act (1974).

7.19 With regards to the co-ordination with other construction projects, Section 3.1 of the

CoCP (Part B) states that a register of projects will be maintained where there is an interface with the Garden Bridge scheme. At present this includes Tate Modern Extension, Blackfriars Tower, Shell Centre Redevelopment and Thames Tideway Tunnel. Dialogue will be maintained with the respective contractors through the TfL Construction Co-Ordination Working Group (Waterloo and Blackfriars) in order to manage risk of construction logistic conflicts or the generation of cumulative adverse environmental impacts. The Council’s Transport Planner and TfL are both satisfied with this approach.

7.20 The process of notifications to local residents, businesses and stakeholders has been

a significant point of interest. In response to this the CoCP (section 3.6) explains that a Community Liaison Officer will be appointed to be the primary point of communication with local residents, businesses and stakeholders throughout the construction period and will take responsibility for day-to-day community engagement.

7.21 A Construction Forum will also be set up and regular meetings held on an individual

basis with representatives of local resident groups, local businesses, property owners and stakeholders. This forum will provide an opportunity for the contractor to disseminate information about upcoming construction activities as well as garner feedback in relation to any concerns that the local community may have in relation to construction matters.

7.22 In addition to the above, the Garden Bridge Trust’s website and social media

accounts will be regularly updated throughout the construction period in order to communicate information about specific works. Furthermore, in advance of significant construction events (such as road closures) or phases of work (concrete pouring), letters will introduce the works, explain when and why they are happening and explain the protocol for raising concerns or queries. This will also be supplemented by a quarterly newsletter to be produced to inform the local community of progress on the construction of the bridge. Hard copies will be distributed to individuals identified on the contractor’s contact list and will be distributed electronically to individuals who have registered on the project website. Officers, including the Council’s Transport Planner, are of the opinion that this is a sound approach to neighbour notification.

7.23 In terms of how complaints and queries are dealt with, the CoCP (section 3.6)

provides specific details and standards. It states that the following will be established in order to provide an outlet for complaints from the public or for fielding questions in relation to the construction process:

A dedicated 24-hour telephone helpline;

Social media accounts; and

Email and postal addresses. 7.24 The details for the above will be published on the Garden Bridge Trust’s website,

displayed on a site notice or information board and via correspondence such as newsletters and leaflets. A contacts log will be established to keep track of all issues, queries or complaints. Calls will be responded to verbally within 24 hours whilst written correspondence will be responded to within 5 working days. Officers are of the opinion that the methodology in dealing with complaints and questions is robust, ensuring a wide range of channels for local residents to raise issues and providing a clear framework for response. To this end it should also be noted that the contractor is a member of the ‘Considerate Constructors Scheme’. In the event that any complaint is not dealt with via the contractor this provides an alternative route for dealing with the matter noting that any contractor which fails to deal with a problem in an effective manner and is in breach of the CoCP, the contractor can be removed from the Considerate Constructors Scheme.

7.25 In relation to air quality, the CoCP has been reviewed by the Council’s Environmental

Health Officer and independently by Waterman Group. Their original comments requested a number of minor changes to the CoCP in order to increase the

monitoring of air quality and ensure more robust mitigation against harm to air quality as a result of the works. Their comments have been incorporated within the updated CoCP and resultantly the air quality details are considered to be compliant with best practice.

7.26 The CoCP provides an overview of the best practice to be adopted by the contractor

in relation to noise and vibration. These have been reviewed by the Environmental Health (Noise) Officer who has raised no objections. Comprehensive noise and vibration monitoring measures are also proposed. This includes a series of unmanned monitors which will continue to take measurements throughout the build programme. Text alerts will be sent to site operatives if ambient noise levels reach threshold levels. This will allow for an immediate investigation into the cause of the elevated noise levels and allow opportunity to remedy the situation.

7.27 For the purposes of clarification, the submitted document has been updated to

propose an additional monitoring station (subject to access and agreement) at Iroko Housing Co-Op which is the closest residential property and lies directly opposite the site entrance.

7.28 As discussed, the CoCP provides details regarding best practice measures to

mitigate against noise and vibration, together with information regarding monitoring to local businesses and residential properties. However given the specific concern over the impact of noise and vibration on the land uses immediately adjacent to the application site it should be noted that the site specific mitigation measures are to be agreed under Condition 10.

7.29 In relation to this, negotiations between GBT and adjacent businesses are

understood to have resulted in the agreement on a number of broad principles, however detailed discussions remain ongoing at the time of writing. Officers are satisfied that the determination of CoCP (Condition 8) does not ‘pre-determine’ the assessment of Condition 10 – which will be assessed on its own merits. To provide further comfort on this the CoCP has been amended to provide the following clarification of the minimum level of detail to be secured under 10:

Physical noise attenuation/mitigation measures within the site compound;

Specific noise attenuation/mitigation measures for ITV and IBM;

Agreement of maximum threshold noise levels with ITV; and

Details of stop/start protocol with ITV.

Conclusion and Recommendation 7.30 In light of the above, officers consider that the environmental aspects of the CoCP,

as well as the specific measures stipulated within the wording of the original condition, are satisfactory. As such officers recommend the approval of the details pursuant to Condition 8 of the parent permission.

8 ASSESSMENT: Application Ref: 15/04315/DET - Condition 11

(Pedestrian/Cyclist Management Plan)

Introduction

8.1 Condition 11 of the parent application (14/02792/FUL) reads as follows:

No development shall commence until such time as a Pedestrian/Cyclist Management Plan (pertaining to the construction phase of the development) has been submitted to and approved in writing by the Local Planning Authority. The Pedestrian/Cyclist Management Plan shall thereafter be operated for the duration of the construction works.

Reason: To ensure appropriate and safe management of pedestrians and cyclists during the construction phase of the bridge, particularly where closure or reduced capacity to the Queen's Walk is proposed (London Plan Policies 6.9 and 6.10, Core Strategy Policies S1, S4 and PN1 and Saved UDP Policy 9). [Note: The details submitted pursuant to this condition will be referred to Lambeth's Planning Applications Committee for a resolution]

8.2 Condition 11 which requires the submission of a Pedestrian & Cyclist Management

Plan (PCMP) was considered to be PAC referable on the basis of the lack of clarity on construction methodology at the time of the determination of the parent application and in particular the impacts on Queen’s Walk. The PCMP builds upon the information provided within the CLP and CoCP with the principle objective of ensuring safe and continuous movement of cyclists and pedestrians within the vicinity of the construction site.

Submitted Document 8.3 The applicant has provided a detailed PCMP in support of this application. This

document has been revised during the assessment period of this application following comments from Lambeth’s Transport Planning Officer, TfL and responses to public consultation. The main headlines of the document are as follows:

Queen’s Walk will remain open throughout the construction period other than 13 occasions when lifting and bridge installation works will require the closure of Queen’s Walk for up to one day at a time due to safety reasons. These closures will be timed to avoid the weekend peak of pedestrian flows along Queen’s Walk. When access is temporarily suspended a signposted diversion will be put in place with traffic marshals on duty to ensure safety at site access points (see Appendix 2).

The hoarding surrounding the site compound would be sited in order to provide a minimum width of 7.6m on Queen’s Walk other than on approximately 10 occasions were the compound would be temporarily (up to 24 hours) increased to in size (in order to facilitate specific construction works) thereby reducing the width of Queen’s Walk to 5m.

Mitigation measures are proposed to further improve pedestrian comfort levels along Queen’s Walk, including a signposted diversion via Upper Ground in order to reduce pedestrian flows passing the construction site on Queen’s Walk. Furthermore, subject to the agreement of Coin St Community Builders (CSCB) all street furniture along this stretch will be carefully removed and stored during the construction period with tree pits covered to provide more walkable space.

‘Considerate cycling’ is permitted along Queen’s Walk however given the reduction in the width of the pathway signs will be erected requiring cyclists to dismount.

Consultation Responses

8.4 At the time of writing 13 objections had been made in relation to this application, including from local resident and one from Waterloo Community Development Group. The objections are summarised within the below table together with an officer response:

Objection Summary Officer Response

There appears to no real provision for cyclists and pedestrian access will be limited due to crowds both on the bridge and as people wait to go on - queues are likely to result in unacceptable congestion in an already extremely congested area. In addition there is inadequate provision for public amenities which was a requirement of the planning permission.

Issues relating to pedestrian/cyclist management during the operation of the bridge are not a consideration of this application to discharge Condition 11 of the parent consent. This application relates to pedestrian/cyclist management during the construction phase only. Details in relation to crowd control and the impact on the surrounding environs of the bridge will be secured through Condition 46.

There is a problem with public consultation as is unreasonable to expect individuals in the community to understand the submitted documents and appendices and the public meetings/events were flawed due to ‘lies’ being told by GBT.

Thorough consultation measures were approved by the LPA and undertaken by GBT in advance of the submission of these applications to discharge the construction related pre-commencement conditions. The ‘Construction Consultation Report’ which explains how public and stakeholder feedback has been considered and where possible it has been taken into account in finalising the submission documents can be viewed on the Council’s website. The content of the consultation material used by GBT is considered by officers to be written in plain English, avoids the use of jargon/technical language as much as possible and was a clear representation of GBT’s proposals at the time of writing. In addition, officers considered it prudent for the LPA to undertake its own separate public consultation despite there being no statutory requirement for the LPA to consult on applications for approval of details reserved by planning conditions. However given the scale of interest in the parent application and the criticism in relation to public engagement on that application it is considered that an additional consultation exercise was considered to be beneficial. The LPA’s consultation exercise

included the distribution of 229 letters to residential properties and businesses within the surrounding environs. This includes residential properties and businesses on Upper Ground, Cornwall Road, Stamford Street, Duchy Street, Coin Street and Waterloo Road. A further 37 consultation letters/emails were also sent to local housing co-operatives, residential amenity groups and local stakeholders within the area surrounding the application site. In addition to the above a press notice was published in the South London Press on 7th August 2015 and 6 site notices were erected within the vicinity of the site.

There are issues with the formatting of the submitted document.

The information presented within the submitted documents is considered to be clearly presented and allows for a thorough assessment of the specific details pursuant to each condition.

There are issues with the way in which certain information is presented including whether the reference to weekend ‘pedestrian flow’ on page 8 is per hour or on a weekend afternoon.

The information presented within the submitted documents is considered to be clearly presented and allows for a thorough assessment of the specific details pursuant to each condition. In relation to pedestrian flows, the PCMP clearly states at paragraph 2.3.2 that pedestrian flows are measure on an hourly rate.

The references to the differing widths of The Queen’s Walk during the construction process is difficult to understand and should be explained through a plan or diagram.

The references to the different widths of Queen’s Walk throughout the construction period are considered to be clearly presented within the submitted documents. Queen’s Walk will remain open throughout the construction period other than 13 temporary closures of up to 24 hours. Throughout the vast majority of the construction period the minimum width of Queen’s Walk will be maintained at 7.6m as demonstrated in Appendix 3. However on 10 separate occasions, the size of the site compound will temporarily increase for a period of 24

hours via a moveable hoarding in order to facilitate specific construction activities. This will temporarily reduce the minimum width of Queen’s Walk to 5m.

The assertion that the minimum width Queen’s Walk will be 5m is false noting that the document stipulates a ‘clear width of 2.97m’.

The minimum width of Queen’s Walk is considered to be an accurate description noting that is describes the physical distance between the site hoarding and the river wall. ‘Clear width’ is a separate description noting that it takes into account the existence of tree trunks, street furniture etc. For the purposes of clarification officers have negotiated an increase in the minimum width of Queen’s Walk (other than on 10 short-term occasions) to 7.6m between the site hoarding and the river wall. This in turn generates two clear channels for pedestrian movements either side of the retained trees. The combined clear width of these channels would be 5.2m. This would increase further to 6.7m if GBT are able to secure additional mitigation measures including the removal and storage of street furniture.

A ‘pedestrian comfort level’ of D on a Saturday peak is alarming noting that a level E is critical and dangerous.

As a result of negotiation, the PCMP has been amended to show the size of the site compound reduced and the width of Queen’s Walk subsequently increased to 7.6m throughout the construction period (other than 10 limited occasions when the width is temporarily reduced to 5m). This is turn increases the amount of clear footway that can be walked on and resultantly the pedestrian comfort level during the weekend peak would improve to ‘C+’. It is acknowledged that TfL’s guidance suggests that this rating is still ‘uncomfortable’ for a tourist attraction. However, it is considered to be a significant improvement from a ‘D’ rating and would allow improved walking speeds, bypassing and bi-directional movement. This has been reviewed by the Council’s Transport Officer who considers this to be an acceptable outcome noting that outside the weekend peak the pedestrian comfort rating would achieve an ‘A’

rating despite the reduced width of 7.6m It should also be noted that the PCMP proposes further mitigation measures to help improve pedestrian comfort along this section of Queen’s Walk during the construction phase. This includes a signposted diversion to encourage pedestrian flows away from Queen’s Walk and around the construction site via Upper Ground and Bernie Spain Gardens. It is also proposed, subject to agreement with Coin Street Community Builders, that street furniture is carefully removed from the site and tree pits are sympathetically covered in order to increase the amount of clear footway available to passing pedestrians. As a result of these additional mitigation measures pedestrian comfort along this section Queen’s Walk would further improve beyond the ‘worst case’ rating as discussed in the previous paragraph.

Objection is made against the assertion that the Queen’s Walk will remain open at all times given that the contractor admits it will be closed on 13 separate occasions.

The submitted details clearly present the fact that Queen’s Walk would be temporarily closed on 13 occasions. These closures are considered to be justified on Health and Safety grounds noting the risks of constructing a bridge which oversail Queen’s Walk. These limited numbers of closures over the course of an anticipated 32 month construction period are considered to be acceptable in the context of the wording of the original condition (which refers specifically to closures of Queen’s Walk) and Condition 7 (which refers specifically to preventing the prolonged closure of Queen’s Walk).

There are no details of the temporary construction ramp which oversails Queen’s Walk – particularly in relation to height and public safety.

The clearance between the temporary footbridge and Queen’s Walk has been confirmed by as 6.8m which is therefore sufficient in order to ensure that it does not compromise the flow of pedestrians immediately below.

The diversion of Queen’s Walk, the most popular National Trail in the country, for the purposes of convenience of construction is

The principle of limited closures to Queen’s Walk is considered to be acceptable noting the wording of the original condition (which refers

unacceptable.

specifically to closures of Queen’s Walk) and Condition 7 (which refers specifically to preventing the prolonged closure of Queen’s Walk). Officers are satisfied that the numbers of closures are justified, limited in time and have been kept to a minimum. In addition sufficient mitigation measures including signposted/marshalled diversions would be put in place during these temporary closures to minimise disruption. Further details of these proposed diversions can be found within Appendix 2.

There is no explanation within the submitted documents why the proposed 5 m width of Queen’s Walk is considered acceptable.

It should be noted that as a result of negotiation the submitted details have been revised in order secure a 7.6m minimum width of Queen’s Walk throughout the construction period (other than on 10 short-term occasions when the width would be temporarily reduced to 5m). The retained width of Queen’s Walk is determined by the size of the construction compound. In relation to this officers are satisfied that the construction compound now covers as small a footprint as possible with staff welfare offices now stacked to minimise their footprint and a fixed luffing crane being utilised as opposed to a mobile crane which needed greater room in which to operate.

Opportunities to admire river views as a result of these proposals will be completely lost.

This is not a material consideration of this application to discharge Condition 11 (Pedestrian/Cyclist Management Plan). The principle of the proposed bridge and its subsequent impact upon strategic views has already been established under the parent planning application.

The pedestrian surveys reference ‘peak hour’ flows. Is this an acceptable method for undertaking a full survey?

Officers, including the Council’s Transport Planning Officer, have reviewed the submitted information in relation to pedestrian flows and are satisfied with the methodology and results. The survey undertakes analysis of pedestrian flows throughout the week. By understanding what the pedestrian movements are during identified peaks it has allowed officers to make a baseline assessment of the impact of construction activities in a

‘worst case scenario’.

There is a clear conflict between passing pedestrian cyclists/pedestrians on Upper Ground and the site access via the IBM/ITV pathway.

The submitted details are considered to demonstrate that any conflict between cyclists, pedestrians and construction traffic would be suitably managed. This is primarily achieved by ensuring that the junction is appropriately marshalled by trained banksmen during the hours of construction operations. It will be a mandatory requirement that all UK logistics operators will be FORS accredited and where possible CLOCS compliant. The submitted information also stipulates that all construction related deliveries and collections carried out by vehicles over 3.5T will be fitted with a range of vehicle safety measures including: seven side sensors which surround the vehicle and detect objects within 0.8m and track their location and proximity to the vehicle; cameras to allow real-time views of blind spots; side-guard rails, audible ‘vehicle turning left’ warnings; and reflective markings and strobe beacons to the rear of the vehicle.

The information contained on site hoardings will only exacerbate the impact upon pedestrian flows with people stopping to take in the displayed information.

The information displayed on the site hoardings will be secured via a site hoarding strategy forming part of the Section 106 legal agreement. The displayed information is only likely to contain supplementary information regarding the Garden Bridge and diversions around the site and officers are satisfied that this is unlikely to have an impact upon pedestrian flows.

The construction activities will have a significant impact upon the use of the riverside as a public amenity space – what it was originally intended for.

The principle of the use of this space for the bridge landing structures and ancillary A1/A3/D1 use is established under the parent planning consent and is not a material consideration for this application to discharge Condition 11 (Pedestrian/Cyclist Management Plan).

Local amenities including the shop on Upper Ground will be seriously congested as a result of the proposed diversions.

This is not a material consideration for this application to discharge Condition 11 (Pedestrian/Cyclist Management Plan). In any case, Queen’s Walk will remain open throughout the construction period other than 13

temporary closures. The majority of pedestrians on the South Bank are therefore expected to remain on Queen’s Walk throughout the anticipated 32 month construction programme.

Vehicular movements within the vicinity of the site will significantly increase once the bridge is opened including deliveries, coaches, taxis etc

Vehicular movements associated with the operation of the bridge not a material consideration for this application to discharge Condition 11 (Pedestrian/Cyclist Management Plan). Details associated with waste management, delivery and servicing will be secured through Conditions 24, 25 and 29 which will be presented to PAC for determination (in advance of construction commencing) at a later date.

It should be Lambeth’s priority to retain the use of the land as public amenity space as originally intended.

The principle of the use of this space for the bridge landing structures and ancillary A1/A3/D1 use is established under the parent planning consent and is not a material consideration for this application to discharge Condition 11 (Pedestrian/Cyclist Management Plan).

The proposed planting on the bridge deck will not enhance the environment of the South Bank.

This is not a material consideration of this application. Specific details regarding landscaping works will be secured under Condition 18 (Landscape Management Plan) prior to the commencement of any landscaping works on the deck of the bridge.

Lambeth Council should not be prepared to invest significant amounts of money into this project.

Issues associated with finance and public funding are not a material consideration for this application to discharge Condition 11 (Pedestrian/Cyclist Management Plan).

Increased numbers of people will undoubtedly result in increased litter in the surrounding area.

Issues associated with refuse and litter are not a material consideration for this application to discharge Condition 11 (Pedestrian/Cyclist Management Plan). Details associated with waste and refuse generated directly by the bridge will be secured under Condition 24 (Delivery and Servicing Management Plan). Furthermore, impacts on the wider South Bank area as a result of additional visitors associated with the bridge will be secured through

Condition 46(Illegal Trading, Anti-Social-Behaviour, Crowd Control and General Enforcement Management Plan). It should also be noted that an annual financial contribution of at least £250,000 will be secured through the S106 in order to mitigate against impacts on the wider area – including additional litter.

The 'intention' for all construction related deliveries and collections to be made by FORS (Fleet Operator Recognition Scheme) accredited operators is not sufficient. Nor is it acceptable "where practicable" to be compliant with recent CLOCS (Construction Logistics and Cyclist Safety) standards. These should be mandatory.

The submitted details have been updated since the original submission. They now state that the contractors logistics partner, FM Conway, have a FORS Gold Standard. This only held by 0.5% of London’s fleet operators and recognises best practice fleet management, including road safety, driver training, cyclist awareness, vehicle specification and CO2 reduction Furthermore, all UK operators who have not achieved FORS must have registered and gained FORS ‘bronze level’ accreditation as a minimum standard within 90 days of an awarded contract. FORS members will be considered favourably in awarding sub-contracts together with those who commit to meet the deadline. Details of the breakdown of anticipated UK operators (FORS accredited) and international operators (non-FORS accredited) will be presented via addendum. In terms of CLOCS standards, it is acknowledged that deliveries and collections will only be compliant with CLOCS standards ‘where practicable’. However this is not a mandatory requirement and there are no grounds for the Local Planning Authority to refuse the application on this basis. It should also be noted that, in order to help safeguard cyclists safety, the CLP stipulates that all construction related deliveries and collections carried out by vehicles over 3.5T will be fitted with a range of vehicle safety measures including: seven side sensors which surround the vehicle and detect objects within 0.8m and track their location and proximity to the vehicle; cameras to allow real-time views of blind spots; side-guard rails, audible ‘vehicle turning

left’ warnings; and reflective markings and strobe beacons to the rear of the vehicle.

Any revised details should be subject to public re-consultation.

There is no statutory requirement to publically consult on applications to discharge the conditions associated with planning applications. However officers have considered it prudent to do so in this case given the level of public interest. Those comments which have been received have fed into the negotiations which have led to the improvements to the submitted documents. Re-consultation on revised applications is not warranted where the changes represent improvements to the original submissions.

8.5 The Council’s Transport Planning Officer was also consulted on the submitted

details. Following clarification on certain issues and the submission of details they have raised no objections.

8.6 Transport for London were also consulted on the submitted details. Following

clarification on certain issues and the submission of details they have raised no objections.

Relevant Planning Policy 8.7 As discussed at para 5.6 the Lambeth Local Plan now has been adopted. The policies

within the Local Plan that are considered to be relevant to this application are listed as follows:

Lambeth Local Plan (September 2015)

Policy D2 Presumption in favour of sustainable development

Policy T1 Sustainable Travel

Policy T2 Walking

Policy T3 Cycling

Policy PN1 Waterloo

London Plan (March 2015)

Policy 6.9 Cycling

Policy 6.10 Walking

Assessment

8.8 The reason listed within the wording of the original condition is clear that the condition

was considered necessary in the first instance in order to ensure appropriate and safe management of pedestrians and cyclists passing through the area during the construction phase of the bridge. Particular emphasis is placed on the operation of Queen’s Walk.

8.9 The PCMP submitted alongside this application is available to view on the Council’s

Public Access Database using the reference number: 15/04315/DET.

8.10 The submitted PCMP has been assessed by the case officer in conjunction with the

Council’s Transport Planning Officer noting the specific implications on pedestrian and cyclist movements. The comments of TfL have also been considered as part of the assessment, together with those submitted as part of the consultation exercise.

8.11 With respect to the impact upon Queen’s Walk as a result of construction activity, it is

noted that there are no prolonged closures as per the original PAC resolution (Condition 7). The construction programme has been designed to ensure that closures of Queen’s Walk are kept to an absolute minimum and limited to 13 separate occasions of up to one day each over the expected 32 month construction programme. These temporary closures are considered to be justified on the basis that they would coincide with particular stages of the construction works including the lifting and installation of the southern section of the Garden Bridge. Having Queen’s Walk open during such work would compromise the safety of passing pedestrians.

8.12 The requirement of a construction compound to accommodate construction logistics

for the southern portion of the bridge will have an impact upon the functioning of Queen’s Walk. Once erected the construction compound will limit the width of Queen’s Walk to a minimum of 7.6m. However this is considered to be a substantial improvement from the scenarios presented at PAC during the consideration of the parent application which included complete closure of Queen’s Walk. It is also an improvement from the original submission pursuant to this condition which proposed a minimum width of 5m. The additional 2.6m width of Queen’s Walk has been achieved on the basis of a reorganisation of the construction compound; in particular a change in the type of crane used which requires a smaller footprint.

8.13 It is acknowledged that there will be approximately 10 occasions during the

construction phase when Queen’s Walk will be temporarily narrowed to 5m in width. This will be achieved using a moveable hoarding extending from the main site compound. These temporary reductions in width are considered to be an acceptable compromise in order to secure the extended width of 7.6m during the course of the construction works on the South Bank.

8.14 In terms of likely pedestrian comfort, this is assessed using TfL’s Pedestrian Comfort

Guidance for London (2010). This document has guidance status only and does not provide definitive thresholds for the acceptability of pedestrian movements. However it does provide a useful tool for how a scheme operates in practice, how it is perceived by users and what the impact is. In relation to this, the comfort level’s reported for this currently unrestricted section of Queen’s Walk is ‘B-’ for a peak weekend afternoon. On a scale of A to E (where A is the most comfortable and E is the least comfortable) ‘B-’ is considered (for a tourist attraction) to equate as an ‘at risk’ classification falling just short of ‘acceptable’.

8.15 The same pedestrian flows have been analysed with the proposed restrictions in width

resultant from the construction works. The originally submitted CLP proposed a minimum width of 5m for Queen’s Walk. At the weekend peak it was anticipated that this reduced width would result in a pedestrian comfort level of ‘D’ which is deemed to be ‘unacceptable’ for a tourist attraction where walking speeds are restricted and reduced and there are difficulties in bypassing pedestrians or moving in reverse flows.

8.16 However as a result of negotiation, the PCMP has been amended to show the size of

the site compound reduced and the width of Queen’s Walk subsequently increased to 7.6m throughout the construction period (other than 10 limited occasions when the width is temporarily reduced to 5m). This is turn increases the amount of clear footway

that can be walked on and resultantly the pedestrian comfort level during the weekend peak would improve to ‘C+’. It is acknowledged that TfL’s guidance suggests that this rating is still ‘uncomfortable’ for a tourist attraction. However, it is considered to be a significant improvement from a ‘D’ rating and would allow improved walking speeds, bypassing and bi-directional movement. This has been reviewed by the Council’s Transport Officer who considers this to be an acceptable outcome noting that outside the weekend peak the pedestrian comfort rating would achieve an ‘A’ rating despite the reduced width of 7.6m

8.17 It should also be noted that the PCMP proposes further mitigation measures to help

improve pedestrian comfort along this section of Queen’s Walk during the construction phase. This includes a signposted diversion to encourage pedestrian flows away from Queen’s Walk and around the construction site via Upper Ground and Bernie Spain Gardens. It is also proposed, subject to agreement with Coin Street Community Builders, that street furniture is carefully removed from the site and tree pits are sympathetically covered in order to increase the amount of clear footway available to passing pedestrians. As a result of these additional mitigation measures pedestrian comfort along this section Queen’s Walk would further improve beyond the ‘worst case’ rating as discussed in the previous paragraph.

8.18 In relation to the impact upon Queen’s Walk it should also be noted that, in comparison

to the original submission, the set-up of the South Bank construction compound has been pushed back from January 2016 to September 2016. This ensures that impact on Queen’s Walk will be over a shorter period than previously anticipated. It also ensures that Queen’s Walk will be fully operational over the peak summer period during 2016.

8.19 As discussed at 8.17, the PCMP details the proposed pedestrian and cyclist diversions

to be carried out throughout the course of the construction period in order to help reduce pedestrian flows along Queen’s Walk. However it also sets out the diversion strategy for the 13 occasions when Queen’s Walk is temporarily closed. This includes a detailed signage schedule and plan which will set out the diversions that pedestrians and cyclists should follow on these occasions.

8.20 The diversions will specifically encourage alternate routes between Queen’s Walk and

Upper Ground through the Royal National Theatre/IBM passageway to the west of the site and Gabriel’s Wharf and Bernie Spain Gardens to the east of the site. This will result in an increased journey distance of up to 75m or approximately 1 minute additional journey time. The PCMP has been revised through the lifespan of the application to include further details of stewarding and marshalling of pedestrians and cyclists at the Upper Ground and Queen’s Walk interfaces.

8.21 The PCMP also addresses pedestrian and cyclist safety for all construction related

deliveries and collections. It states that it is intended that all such vehicle movements will be undertaken by FORS (Fleet Operator Recognition Scheme) accredited operators (UK operators only) and where practicable, compliant with the most recent CLOCS (Construction Logistics and Cycle Safety Project) standards. Details regarding the breakdown between anticipated UK logistics operators and international operators will be presented via an addendum to provide clarity in relation to FORS accreditation.

8.22 The PCMP explains that the local logistics and traffic management contractor, FM

Conway, maintains FORS Gold accreditation and is one of only three organisations in Europe to have achieved certification to ISO 39001: Road Safety Management Systems which is an international standard recognised at reducing death and serious

injury on roads. The PCMP states that the contractor will leverage supply chain relationships to maintain an up to date knowledge of local issues, safety initiative and best practice through CLOCS. FM Conway are a member of the CLOCS project board and are represented on all CLOCS working groups. The PCMP explains that all vehicles over 3.5T will be fitted with the latest vehicle safety measures including:

Seven side sensors which surround each vehicle to detect objects within 0.8 metres and track their location and proximity to the vehicle

A near-side blind spot camera, which allows the driver to view real-time images of blind spots on the left-hand side of the truck;

A reversing camera which covers the blind spot at the rear of the vehicle;

Side-guard rails which reduce the potential for pedestrians or cyclists to be dragged under the vehicle’s back wheels when HGVs turn left;

An audible “vehicle turning left‟ warning to pedestrians and cyclists High visibility warning signs; and

Reflective markings and strobe beacons at the rear of the vehicle.

Conclusion and Recommendation 8.23 In light of the above, officers consider that the PCMP demonstrates that the impact on

passing pedestrians and cyclists has been mitigated as much as possible, that suitable diversions are proposed during temporary closures of Queen’s Walk and the IBM/ITV passageway and that appropriate safety measures will be taken in relation to stewarding and vehicle movements. As such officers recommend the approval of the details pursuant to Condition 11 of the parent permission.

9 ASSESSMENT: Application Ref: 15/04316/DET - Condition 12 (Tree Removal

Plan)

Introduction

9.1 Condition 12 of the parent application (14/02792/FUL) reads as follows: Prior to the commencement of development hereby approved a plan showing the trees

which are to be removed in relation to the final construction option shall be submitted to and approved in writing by the Local Planning Authority. The number of trees to be removed shall not exceed that set out for each construction option as detailed within Volume 3 Appendix 1 of the Environmental Statement (May 2014) unless otherwise agreed in writing with the LPA.

Reason: To ensure the retention of, and avoid damage to, the retained trees on the site which represent an important visual amenity to the locality (Saved UDP Policies 31, 33, 38 and 39 and Core Strategy Policies S1, S9 and PN1).

9.2 This condition was originally imposed on the basis that there was a lack of clarity over

construction methodology at the time of the determination of the original application and the subsequent impact upon trees within the immediate vicinity of the application

site. Each construction option would have varying impacts on trees in this location, both on Queen’s Walk and the adjacent landscaped area in front of ITV studios. The condition requiring a Tree Removal Plan was imposed in order to confirm which trees would be removed as a result of the works.

Submitted Document 9.3 The applicant has submitted an Outline Arboricultural Method Statement (AMS)

prepared by Landmark Trees (ref. TFL/TGB/AMS-SB/02h) dated 9th November 2015. This is a revised version of the document which was received on 19th August 2015.

9.4 At the time of the original planning permission, it was anticipated that a total of 27 trees

would need to be removed as a result of Construction Option A (utilising the ITV/IBM passageway). However, when the contractor was appointed in April 2015, they identified that T76 (London Plane) also required removal in order to permit safe access to the site.

9.5 As such, by way of comparison to the details submitted as part of the original planning

application, the applicant now intends to fell a total of 28 trees. The AMS also states that three trees (T50, T76 and T83) would be replaced following construction by three semi-mature London Plane trees. This results in a net loss of 25 trees. Full details of the proposed trees to be felled, including a comparison with the trees to be removed under Construction Option A as presented within the original planning application, can be found within the table below:

Tree Number

Specimen Category (NB. Cat A being the highest grade of tree)

Action as per Planning Application (Construction Option A) (May 2014)

Action as per Revised Arboricultural Method Statement (November 2015)

49 London Plan B Keep Keep

50 Laburnum C Fell Keep

51 Cherry Flowering C Fell Fell

52 Cherry Flowering C Fell Fell

53 Cherry Flowering C Fell Fell

54 Cherry Flowering C Fell Fell

55 Silver Birch C Fell Fell

56 Silver Birch C Fell Fell

57 Silver Birch C Fell Fell

58 Silver Birch C Fell Fell

59 London Plane B Keep Fell (Replace with London Plane Tree)

63 London Plane B Fell Fell

64 London Plane B Fell Fell

67 London Plane B Fell Fell

69 London Plane B Fell Fell

70 London Plane B Fell Fell

71 London Plane B Fell Fell

72 London Plane B Fell Fell

75 London Plane B Fell Fell

76 London Plane B Keep Fell (Replace with

London Plane Tree)

83 Robinia B Fell (Replace) Fell (Replace with London Plane Tree)

84 Cherry Flowering C Fell Fell

85 Cherry Flowering C Fell Fell

86 Cherry Flowering C Fell Fell

87 Cherry Flowering C Fell Fell

88 Horse Chestnut C Fell Fell

89 Cherry Flowering C Fell Fell

90 Cherry Flowering C Fell Fell

91 Cherry Flowering C Fell Fell

92 Cherry Flowering C Fell Fell

Total Loss 27 28

Replacements 1 3

Net Loss 26 25 9.6 Since the time of the original submission of this application, amendments have been

proposed which include changes to the site compound in order to allow for the widening of the walkway along Queen’s Walk during construction. In this respect, the site hoarding would be recessed further, therefore allowing a minimum 7.6m clearance (as opposed to 5m as originally proposed) between the proposed site hoarding and the river wall. The “reduced” site compound area would allow an additional 2.6m clearance to facilitate a more convenient flow of pedestrians and cyclists along Queen’s Walk during the construction phase period as discussed within Section 8 of this report.

9.7. A series of amendments have been made to the AMS as a result of this increase in the

width of Queen’s Walk (in comparison to the original submission) and the subsequent reduction in the size of the site compound. In particular the contractor has identified the need to use a stationary tower “luffing” crane for construction purposes as opposed to the mobile crane as originally proposed (which required additional room for manoeuvring).

9.8 To accommodate the stationary crane it will also be necessary to prune the southern

side of the crowns of the following London Plane trees: T60, T61, T62, T65, T66, T68, T73, T74, T77, T78 and T79 back to the hoarding line in order to allow for safe crane movement and prevent harm to the tree canopies.

9.9 As a further result of the proposed changes, the staff welfare cabins will be positioned

to the northeast corner of the site and will be double stacked to minimise the area which they cover. This means that will no longer be necessary to remove tree’s T49 (London Plane) and T50 (Laburnum) as proposed within the AMS originally submitted with this application.

9.10 For the purposes of clarification, it should be noted that the consultation exercise

undertaken by the applicant prior to the submission of this application included a net loss of 26 trees, including a total loss of 29 and the replacement of three. However as a result of negotiations to lessen the footprint of the site compound, and maximise the width of Queen’s Walk, this has required a number of changes in site layout resulting in a net loss of 25 trees, including the total loss of 28 trees and the replacement of three.

Consultation Responses

9.11 At the time of writing, a total of 14 objections have been received in response to the public consultation exercise. The objections are summarised below, together with a corresponding response:

Objection Summary Officer Response

The removal of any healthy mature trees runs contrary to the principle of a Garden Bridge. There are approximately 30 mature trees in the space where the building for the bridge is proposed. One objection also refers to 40 trees being removed.

The principle of the loss of mature trees to facilitate construction and the physical bridge structures themselves has already been accepted under the parent planning consent. For the purposes of clarification, 28 trees would be felled as a result of the works with three trees being replaced resulting in the net loss of 25 trees.

Even if new trees are planted these will take years to mature and will be restricted in terms of growth and development due to this location.

The proposed replacement trees are London Plane trees which would be semi-mature trees at the time of planting with a girth of 20-25cm. This would ensure the trees are of a sufficient size at the time of planting. The Council’s Tree Officer is satisfied that these replacement trees will be acceptable and would not be adversely restricted in terms of their growth and development potential.

The available drawings suggest very little depth to the planting.

This is not a material consideration of this application. Specific details regarding landscaping works will be secured under Condition 18 (Landscape Management Plan) prior to the commencement of any landscaping works on the deck of the bridge.

How can we fully comment on trees without full information on South Landing Building? If the South Landing Building were of a different footprint perhaps some further trees could be saved? Without fuller discussion about the South Landing Building the removal of these trees cannot be justified.

Again, the current application relates solely to the tree removal plan pursuant to Condition 12 of planning permission (Ref. 14/02792/FUL). Details of the proposed South Landing Building will form part of a future DET application submission which is expected to be submitted in December 2015. In any case, the size and footprint of the South Landing Building has already been established under the original application and the loss of the trees positioned within this footprint has therefore been accepted in principle. This application seeks clarification on any additional to be removed as a result of construction works.

Given the reason that these trees are to be removed include the provision of staff/site cabin facilities, could another location not have been utilised in order to save protected trees entirely? Has an alternative option on this area been considered in order to ensure as minimum loss of trees as possible. The protection of trees should be high priority.

The original submission pursuant to this condition proposed the removal of T49 and T50 as a result of the installation of the site welfare offices and services. However as a result of a reconfiguration of the layout of the site compound these trees will now be retained. Officers are scrutinised the proposals in detail and are satisfied that this is the minimum number of trees that can be removed as a result of the construction works.

Object to the felling of 26 mature trees on the Queens Walk. The council are trustees of this land and should not be destroying trees to make way for a huge private Garden bridge. Public money should not be wasted on destroying what the people of Waterloo have fought to keep for the public good.

The principle of the removal of 27 trees has previously been agreed by virtue of the original planning permission.

Damage will be done to many trees and shrubs by the enormous number of cement mixers, delivery lorries and trucks, material storage, soil pollution and compaction, excavation and lifting machinery, parking, plant machinery, hosing down, and the tramping of countless boots of construction workers.

Details regarding tree protection measures throughout the construction process will be secured under Conditions 13 (Tree Protection Plan) and 16 (Tree Protection Monitoring).

The proposed replacement trees and those on the bridge would not survive the buffeting of salt water icy high winds out on the river Thames.

The Council’s Arboricultural Officer has raised no concerns regarding the three replacement trees forming part of the submitted details. These three trees would be semi-mature London Plane species which are a proven species in this location. The proposed landscaping of the bridge deck is not a material consideration under this application. These details will be secured under Condition 18 (Landscape Management Plan) prior to the commencement of any landscaping works on the deck of the bridge.

Trees are an integral part of the riverside walk, view and open space as it has developed. The construction period will have significant and negative impact upon trees in this socially valuable public space and riverside walk. This development threatens us with major tree loss. Tree root damage is an immediate serious potential and our understanding is that the trees were planted in trenches and grow entangled. Not only is there immediate danger when one tree is cut down but there is serious potential for damage from people, dust, pollution, chemicals, deliveries, fuels, oils, solvents, tar, fires, drainage and contamination. Further investigation is essential in respect of root protection. The South Bank is to remain a public space and the view of St. Pauls to stay intact. I can think of no other occasion where a council would sanction the removal of healthy trees.

Details regarding tree protection measures throughout the construction process will be secured under Conditions 13 (Tree Protection Plan) and 16 (Tree Protection Monitoring). Views of St Paul’s Cathedral are also not relevant to the assessment of this application. The objector’s comments regarding the removal of healthy trees are noted however the principle of the net loss of 26 mature trees has already been established under the parent consent. This application is considered to be betterment in comparison noting that there would be a net loss of 25 mature trees as a result of the proposed works.

9.10 The Council’s Tree Officer was consulted on the submitted details. Following

clarification on a number of matters the officer has since confirmed that the details submitted are satisfactory and that it is recommended that the condition can be discharged.

Relevant Planning Policy

9.12 As discussed at para 5.6 the Local Plan (2015) has since come into effect, and is the

document by which planning decisions are based upon (along with national and regional policies). The policies within the Local Plan that are considered to be relevant to this application are listed as follows:

Lambeth Local Plan (to be adopted September 2015)

Policy D1 Delivery and monitoring

Policy D2 Presumption in favour of sustainable development

Policy EN1 Open Space

Policy Q9 Landscaping

Policy Q10 Trees

Policy Q22 Conservation Areas

Policy PN1 Waterloo

Assessment

9.13 This condition was imposed because the exact number of trees to be removed was

dependent on the final construction option selected by the applicant. The construction option had not been confirmed at the time the PAC determined the parent application and instead the Committee was presented with three different

scenarios, Option’s A, B and C. Each option was presented to members in terms of how many trees would have to be removed to facilitate the construction phase.

9.14 The applicant has since identified construction option A as the preferred construction

option which would utilise the walkway between ITV and IBM. It is noted that two additional trees are proposed for removal compared to those originally identified for removal within the details submitted in support of the parent application. These additional trees are London Plane trees (T59 and T76). The wording of condition 12 provides flexibility in the number of trees to be removed by including the clause ‘unless otherwise agreed in writing’. The Council’s Tree Officer does not object to these additional trees being removed on the basis that three new trees would be planted once construction has been completed and that T50 (which was previously identified for removal) would now be retained. The replacement trees will be 20-25cm girth London Plane semi–mature trees and would help ensure that any temporary adverse impacts on the visual amenity of the area arising from the loss of these additional trees are mitigated in the long-term. These three replacement trees also secure a reduction (of one) in the net numbers of mature trees being lost by the works in comparison to the details presented alongside the parent planning application.

9.15 It is noted that the submitted AMS was updated through the assessment period in

order to reflect the reduction in the size of the proposed construction compound and the subsequent increase in width of Queen’s Walk from 5m to 7.6m. The reduction in the size of the site construction compound has been presented in order to alleviate concerns of congestion (“bottlenecking”) of pedestrians along the South Bank during the proposed construction phase. In order to facilitate the reduced site compound area, a number of trees will need to be pruned back to accommodate the hoarding and equipment.

9.16 In this respect, it should be noted that T49 (4m), T50 (1m), T60 (8m) and T61 (8m)

will need to be pruned (the amount of pruning is indicated in brackets) in order to provide sufficient space / clearance for the revised site hoarding location (owing to the reduced site compound area). Furthermore, to enable construction operations within the smaller site compound, a luffing crane with a 6m x 6m footprint would be required. As such, trees T62 (2.5m), T65 (0.5m), T66 (2.5m), T68 (2.0m), T73 (3.0m), T74 (2.0m) would be pruned back whilst T77, T78 and T79 would be pruned (to accommodate the temporary footbridge), in order to facilitate full clearance.

9.17 In terms of the pruning implications, it is acknowledged that the trees will look

foreshortened. However, the requirements are well within the allowance of best practice (BS3998:2010) and tolerance of the individual species which has been carefully considered so that there will be no lasting harm. Furthermore, visual amenity will be safeguarded given the fact that the foreshortened crown faces of the trees will be to the south, facing the construction site, rather than the sensitive river frontage. The applicant has stated that the crowns can be trained to recover their natural proportions over the next few growth seasons, which will be largely throughout the duration of the construction period. Finally, given the circa 2-year construction period on, the applicants have accepted that any further pruning for working clearances must be discussed first with the Council’s Arboriculturalist, and once agreed in principle these works will be need to be approved by the tree officer, and subsequently approved in writing by the LPA through a re-discharge of this condition.

Conclusion and Recommendation

9.18 In light of the above, officers consider that the revised AMS would accord with the

intent of the condition. As such officers recommend the approval of the details pursuant to Condition 12 of the parent permission.

Background documents – Case file (this can be accessed via the planning Advice Desk, Telephone 020 7 926 1180). For advice on how to make further written submissions or to register to speak on this item, please contact Democratic Services, 020 796 2170 or email.

Appendix 1: Garden Bridge in context (enlarged image taken from approved plan ref: HS-A-P-0010 Rev. A)

Appendix 2: Pedestrian and cyclist diversions during temporary closures of Queen’s Walk (enlarged image taken from CoCP (Part B) – Appendix A)

Appendix 3: South Bank construction compound demonstrating 7.6m retained width of Queen’s Walk (enlarged image taken from CLP – Appendix B)

Appendix 4: Construction access via IBM/ITV pathway accommodating 2m wide ITV queue and construction traffic (enlarged image taken from CLP – Appendix H)

Appendix 5: Construction routes (enlarged image taken from CLP – Appendix D)